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Home My WebLink About1.00 General Application Materials_Part2LATHAM, THOMAS F & GINGER L CAERUS PICEANCE LLC COUEY FAMILY LLLP LARAMIE ENERGY LLC BLM T 6 S T 5 S R 97 W0 2000 VICINITY MAP LARAMIE ENERGY, LLC. CC 610-21-41 NENW, SECTION 10, T.6 S., R.97 W., 6th P.M., GARFIELD COUNTY, COLORADO 1414 ELK ST., ROCK SPRINGS, WY 82901 RIFFIN & ASSOCIATES, INC. (307) 362-5028 VICINITY DRAWN: 5/12/2022 - DEH DRG JOB No. 21293REVISED: N/A SCALE: 1" = 2000' GARFIELD CO., COLORADO QUADRANGLE NORTH MAMM PEAK RULISON VICINITY MAP CC 610-21-41 PAD EXISTING PRIVATE SITE SPECIFIC ACCESS ROAD EXISTING PRIVATE ACCESS ROADS NOTE: NO PUBLIC UTILITY SYSTEMS, RESIDENTIAL DEVELOPMENT, PUBLIC ROADS, OR MUNICIPALITIES EXIST WITHIN A 1-MILE RADIUS OF THE PERMITTED SITE. CC 610-21-41 PAD LAT: 39° 32' 39.57" N LONG: 108° 12' 25.34" W COUEY FAMILY LLLP 216910100020 CC 604-44(04-16Laramie) CC 610-21-41 CC 603-23-32(03-14Laramie) L13 L16 L15 L14 L13 L16 L15L14 NWSE SWSE NWNE SWNE 6S 97W NESE NWSW NESW NWSE NESE NWSW NESW SESE SWSW SESW SWSE SESE SWSW SESW NENE NENE NWNWNWNENENWNWNW NENW SENE SWNE SENESENWSWNW SWNW SENW 03 111009 04 02 ± T7S-R97W Garfield County, Colorado Update Date: 4/28/2022 Coordinate System: NAD 1983 StatePlane Colorado Central FIPS 0502 Feet Document Path: L:\GIS\GIS_Staging\LandMapping2022\Landmaps_22\Laramie N Cascade_PadOffsets_22_r2.mxd0 0.25 0.50.125 Miles New Road Existing Road Rig Planning Pads 200 FT PAD SITE BUFFER Existing Wellpad Existing Pond Closed Pond Couey Surface LaramieLeaseholdTracts BLM USFS Surface Parcels Garfield Co PERMITTED PAD SITE BUFFERSCOUEYFAMILY LLLP216910100030COUEYFAMILY LLLP216910100030COUEYFAMILY LLLP216910100030 Laramie Energy, LLC Emergency Action Plan Corporate: Laramie Energy, LLC 1401 Seventeenth St. Suite 1400 Denver, Colorado 80202 Field: 760 Horizon Drive, Suite 101 Grand Junction, Colorado 81506 TABLE OF CONTENTS Emergency Action Plan .......................................................................1 PURPOSE ............................................................................................................................................................ 1 OWNERSHIP ........................................................................................................................................................ 2 GENERAL, ON-SITE RESPONSIBILITY ......................................................................................................................... 2 DRILLING OPERATIONS, ON-SITE RESPONSIBILITY ....................................................................................................... 3 COMPLETION OPERATIONS, ON-SITE RESPONSIBILITY .................................................................................................. 3 EMERGENCY PHONE NUMBERS AND CONTACTS (TABLE 1) ......................................................................................... 4 Emergency Procedures: FIRE/EXPLOSION ................................................................................5 HAZARDOUS MATERIALS RELEASE ......................................................5 VEHICLE ACCIDENT .............................................................................6 PERSONAL INJURY ..............................................................................6 SUDDEN ILLNESS OR DEATH ...............................................................7 1 Emergency Action Plan The management of Laramie Energy is genuinely concerned with the health and welfare of all personnel who enter oil and gas field operations including company employees, customer employees, contractors, contractor’s employees, visitors to the premises and the general public. While Laramie Energy engages professional contractors and drilling contractors and relies upon their expertise and their own, published, Emergency and Safety Plans, it is essential for all Laramie Energy personnel and associates to know what to do in the event of an emergency in order to minimize danger. Purpose The purpose of this emergency action plan is to provide employees and contractors working at Laramie Energy sites with emergency procedures and phone numbers for local emergency response agencies that should be contacted in the event of an emergency at a Laramie Energy work site. This Emergency Action Plan may be published independently from the Safety Plan as needed. Requirements (per 29 CFR 1910.38(c)) • Means of reporting fires and other emergencies – Laramie employees must use any means possible to contact emergency services if necessary. Cell phones, company radios, land lines and satellite phones may be used to accomplish this goal. In offices, the manual fire alarm may be pulled. All fires and incidents must be reported to the appropriate supervisor and safety department as soon as possible. • Evacuation procedures and emergency escape route assignments – written procedures and route assignments are available for larger facilities and offices. In occupied offices, you must close your door as you exit your office. A floor warden will ensure that the office floor is completely evacuated and will be the last employee to vacate the office area. Evacuation of smaller sites, such as well pad locations must be addressed during a project pre-job meeting. • Procedures for employees who remain to operate critical plant operations before they evacuate – Laramie employees will initiate shutdown procedures per facility in the event of an emergency evacuation. Laramie employees will be expected to evacuate when the signal is given. • Accounting for all employees after an emergency evacuation has been completed – the supervisor on site (or most senior employee if the supervisor is not present) will be responsible to account for all employees and contractors on site during an evacuation to ensure that everyone has safely evacuated. • Rescue and medical duties for employees performing them – Employees will be expected to perform rescue and medical duties to the level in which they were trained. Employees will be expected to not perform above their training level. • Names or job titles of persons who can be contacted: 2 Ownership OWNER RESPONSIBLE PARTY Laramie Energy, LLC 1401 Seventeenth St. Suite 1400 Denver, Colorado 80202 Office: 303-339-4400 Fax: 303-339-4399 Robert S. Boswell Chairman & Chief Executive Officer Office: 303-339-4401 Cell: 303-517-1774 General, On-Site Responsibility DENVER OFFICE RESPONSIBLE PARTY Denver Emergency 911 Laramie Energy Office 303-339-4400 Building Security 720-300-1150 Property Management 303-382-1331 GRAND JUNCTION OFFICE RESPONSIBLE PARTY Laramie Energy, LLC 760 Horizon Drive, Suite 101 Grand Junction, Colorado 81506 Phone: 970-263-3600 Chris Clark Vice President- Field Operations Office: 970-263-3607 Cell: 970-462-8375 NORTH PICEANCE OFFICE - DEBEQUE RESPONSIBLE PARTY Laramie Energy, LLC 4321 V 2/10 Rd. DeBeque, Colorado 81630 Phone: 970-263-3655 Eric Lane North Area Production Manager Office: 970-812-5313 Cell: 970-640-9172 3 SOUTH PICEANCE OFFICE- COLLBRAN RESPONSIBLE PARTY Laramie Energy, LLC 6645 64 6/10 Road Collbran, Colorado 81624 Phone: 970-487-0298 Fax: 970-487-3843 Milt Johnson South Area Production Manager Office: 970-487-3897 Cell: 970-230-1011 Fax: 970-487-3585 Home: 970-268-5503 or 970-487-0261 Drilling Operations, On-Site Responsibility DRILLSITE RESPONSIBLE PARTY Varies (to be shared during drilling activity) Aaron Duncan Drilling Manager Office: 303-339-4913 Cell: 406-498-4526 Completion Operations, On-Site Responsibility COMPLETION SITE RESPONSIBLE PARTY Varies (to be shared during completion activity) John Grubich Completions/Production Engineering Manager Office: 970-812-5312 Cell: 970-589-9496 Home: 970-245-1656 4 Emergency Phone Numbers and Contacts This section provides a list of emergency phone numbers that should be used in the event of an emergency at one of Laramie Energy’s field locations. Please note that the different Laramie Energy field locations have different local emergency response numbers. Table 1 – Emergency Phone Numbers DeBeque Area Collbran Area CareFlight 1 (800) 332-4923 CareFlight 1 (800) 332-4923 Mesa County Sheriff 970-242-6707 Mesa County Sheriff 970-242-6707 Saint Mary’s Hospital 970-244-2273 Saint Mary’s Hospital 970-244-2273 Grand River Hospital 970-625-6400 Community Hospital 970-242-0920 DeBeque Fire Dept. 970-283-8632 Plateau Valley Fire Dept. 970-268-5283 Non-Emergency 970-242-6707 Non-Emergency 970-242-6707 Colorado State Patrol 970-249-4392 Colorado State Patrol 970-249-4392 Buckhorn Draw Area CareFlight 1-800-332-4923 Rio Blanco County Sheriff 970-878-9625 Pioneers Medical Center 970-878-5047 Meeker Fire Dept. 970-878-3443 Non-Emergency 970-878-9600 Colorado State Patrol 970-826-1301 All Denver area emergencies – call 911 5 EMERGENCY PROCEDURES FOR: FIRE/EXPLOSION 1. KEEP CALM! In your haste to act, you may injure others or yourself. 2. Drilling Supervisor, Completion Supervisor, or Area Production Manager is in charge. 3. Evacuate and follow directions to a safe location. 4. Contact the appropriate local emergency response authorities from Table 1: 5. Follow directives of Sheriff, Ambulance and/or Fire Department personnel upon arrival. 6. Be available to support supervisor’s directives, including assisting with fire extinguishing and evacuation of injured personnel if trained and able. 7. Contact Area Production Manager by phone if not already onsite or previously contacted. 8. Contact Chris Clark, Vice President- Field Operations, at 970-462-8375 (cell) if not previously contacted. 9. Contact Robert Boswell, Chief Executive Officer, at 303-517-1774 (cell) if not previously contacted. HAZARDOUS MATERIALS RELEASE 1. KEEP CALM! In your haste to act, you may injure others or yourself. 2. Make sure the area is safe. If a confined area, verify that atmosphere is breathable before entering.  Assess the situation:  Is anyone injured?  What materials were released?  Are surface runoff waters impacted? 3. Depending on conditions:  If a serious injury or an associated fire: - Call appropriate emergency response authorities from Table 1.  Relay nature of emergency, location and travel instructions.  If drilling or completion rig/materials/personnel are involved, Notify: - The Drilling or Completions Supervisor and/or - The Area Production Manager 4. If release is manageable, use materials on hand to control and contain the release. 5. Follow procedures in Spill Prevention, Control and Countermeasures Plan. 6. Ensure that all communications notices have been made. 6 VEHICLE ACCIDENT 1. KEEP CALM! In your haste to act, you may injure others or yourself. 2. Make sure the vehicle is secured. Take notice of risk of fire or of shifting loads. 3. Assess the situation:  Is anyone hurt?  Have any hazardous materials been released?  Provide first aid to injured personnel to your training level. 4. Take steps to control traffic in area. 5. Depending on conditions:  If a serious injury or associated fire, call appropriate emergency response authorities from Table 1;  Identify the nature of the emergency, location and travel instructions.  If no injury or minor injury, document information and provide medical attention.  If on public roads, call local Sheriff from Table 1.  If reasonable, remove damaged vehicle from public thoroughfare. 6. Ensure that all communications notices have been made. PERSONAL INJURY 1. KEEP CALM! In your haste to act, you may injure others or yourself. 2. Make sure the area around injured person is safe. If a confined area, verify that atmosphere is breathable before entering. 3. Assess the condition of the injured. 4. If a serious injury, call the appropriate emergency response authorities from Emergency Notification Chart:  Nature of emergency, location and travel instructions.  Designate a well-known local site to meet incoming ambulance to guide to site.  Use map for surface transportation.  In case of major incident; use latitude-longitude or well known, easy-to-recognize landmark for helicopter response. 5. If drilling or completion rig/materials/personnel are involved, Notify:  The Drilling or Completion Supervisor and/or  The Area Production Manager. 6. Provide first aid to injured personnel to your training ability. 7. Ensure that all required notifications have been made. 7 SUDDEN ILLNESS OR DEATH 1. KEEP CALM! In your haste to act, you may injure others or yourself. 2. If ill worker is conscious and able to respond: • Make sure the area around ill person is safe. If a confined area, verify that atmosphere is breathable before entering. • Remove ill worker from harm’s way. Protect from extremes of temperature. Assure continued breathing. • Inquire as to the nature of the illness, attack or symptoms and available medication if needed. • Administer first aid to your training ability. • Call appropriate emergency response services from Table 1. 3. If ill worker is unconscious or unable to respond: • Make sure the area around ill person is safe. If a confined area, verify that atmosphere is breathable before entering. • Remove ill worker from harm’s way. Protect from extremes of temperature. Assure continued breathing. • Inquire of friends or co-workers as to the nature of the illness, attack or symptoms. • Inquire of friends or co-workers as to available medication if needed. • Administer first aid to your training ability. • Call appropriate emergency response services from Table 1. 4. Notify the Drilling Supervisor, Completions Supervisor, or Area Production Manager. 5. Contact Chris Clark, Vice President – Field Operations, at 970-462-8375 (cell) if not previously contacted. 6. Contact Robert Boswell, Chief Executive Officer, at 303-517-1774 (cell) if not previously contacted. 7. If a hospitalization, fatality, amputation or loss of an eye occurs, the Chief Operating Officer or his/her representative must notify OSHA within 8 hours of such incident. Emergency Notification Chart Operations & Facilities Completions John Grubich Completions Mgr C 970-589-9496 O 970-812-5312 Drilling Aaron Duncan Drilling Manager C 406-498-4526 O 303-339-4913 First Responder: contact emergency services as necessary 911. Direct Dispatch numbers are listed below. **Verbal contact MUST be made or move to next person in line. Voicemail, email or text are not acceptable for emergency notification** Chris Clark VP-Field Operations C 970-462-8375 O 970-263-3607 Wayne Bankert Regulatory & Env Manager C 970-985-5383 O 970-812-5310 Laura Lancaster Health & Safety Coordinator C 970-644-1259 O 970-263-3627 Eric Lane North Prod Mgr C 970-640-9172 O 970-812-5313 Milt Johnson South Prod Mgr C 970-230-1011 O 970-263-3665 Mesa County Dispatch (Debeque/Collbran) 970-242-1234 Garfield County Dispatch (Rifle) 970-625-8095 Rio Blanco County Dispatch (Buckhorn Draw/Piceance) 970-878-9625 St. Mary’s Careflight 970-332-4923 Poison Control Hotline 800-222-1222 Chemtrec 800-424-9300 For spills, environmental, wildlife For injury, fire, vehicle, damage SOUTH NORTH Laramie Health and Safety Manual October 2020 2 Table of Contents Sec 1 INTRODUCTION Sec 2 SAFETY AND HEALTH MANAGEMENT SYSTEM Sec 3 PERSONAL PROTECTIVE EQUIPMENT Sec 4 VEHICULAR OPERATIONS Sec 5 WALKING AND WORKING SURFACES Sec 6 HAZARD COMMUNICATION Sec 7 CONTROL OF HAZARDOUS ENERGY SOURCES Sec 8 PERMIT REQUIRED CONFINED SPACES Sec 9 FIRST AID/CPR/BBP Sec 10 FALL PROTECTION Sec 11 ERGONOMICS Sec 12 ELECTRICAL SAFETY Sec 13 HYDROGEN SULFIDE Sec 14 EXCAVATION/GROUND DISTURBANCE Sec 15 HOT WORK Sec 16 FORKLIFT/INDUSTRIAL TRUCKS Sec 17 POWER AND HAND TOOLS Sec 18 MACHINE GUARDING Sec 19 FIRE PREVENTION Sec 20 CONTRACTOR MANAGEMENT Sec 21 EMERGENCY RESPONSE Sec 22 EXTRA TOPICS (housekeeping, compressed gas cylinders, liquids handling & transfer operations, fueling, pipeline & gathering systems, well completion & drilling operations) 3 Section 1 INTRODUCTION I. Purpose The purpose of this Introduction is to define and implement a Field Safety and Health Management System and appropriate safety and health programs, as identified in the subsequent sections for Laramie Energy. Laramie Energy is responsible for ensuring that employees of the company have a safe and healthful workplace that complies with the Occupational Safety and Health Act and with OSHA standards. II. Scope The instruction applies to all Laramie Energy employees. III. References A. Occupational Safety and Health Act, Public Law 91-596, December 29, 1970; as amended by Public Law 101-552, November 5, 1990; as amended by Public Law 105- 241, September 29, 1998. B. Presidential Executive Order 12196 of February 26, 1980; Title 29: Subtitle B – Regulations Relating to Labor. V. Revision History The table below lists all changes made to this section since the implementation of the program: 4 Section 2 SAFETY AND HEALTH SYSTEM SAFETY AND HEALTH MANAGEMENT SYSTEM I. Management Commitment and Leadership II. Employee Participation III. Worksite Analysis IV. Incident Reporting/Investigation Procedures V. Hazard Prevention and Control VI. Safety and Health Training VII. Specific Safety and Health Programs VIII. Revision History In general, it is Laramie Energy’s belief that: • The safety of people is more important than any property or business objective. • All workplace accidents can be prevented through proper training, planning and preparation. • Safe behavior while at work is a condition of employment. • Safety is the responsibility of all employees and contractors. Everyone should strive to improve the safety of the workplace. Laramie Energy uses professional contractors and consultants for many exploration and production related operations including: • Surveying; • Well pad, road and pipeline construction; • Well drilling, well completion and well work over activities; • Transporting produced fluids; and • Maintenance activities. By engaging these contractors and consultants to provide their professional services, Laramie Energy thereby relies upon their specific expertise, and their own Health and Safety Plans and employee training procedures to address their activities. However, it is essential that all of the Company’s personnel and associates conduct their activities in a manner that is consistent with the general safety policies established by the Company and in accordance with the Health and Safety Program and Procedures described in this plan. General Safety Policies All employees or contractors of Laramie Energy are required to perform their assigned duties in accordance with the following general safety policies: 5 1. Laramie Energy requires all employees and contractors to be fully trained and knowledgeable of their assigned duties. This includes all applicable requirements for safety, health and environmental protection associated with the full scope of the Employee’s work. 2. Any work task that potentially may expose an employee (s) to hazardous materials will be conducted only after developing a site-specific Health and Safety Plan (HASP) per OSHA requirements. 3. Smoking on company property is prohibited except in designated areas. 4. Intoxicants, narcotics or illicit drugs shall not be consumed or possessed while using company equipment, working on a job site, or while working on a company project. All Employees must comply with the directives stated in the Company’s Anti-Drug Plan and Alcohol Misuse Plan. 5. Firearms of any kind are prohibited on company property, including the possession of a firearm in a vehicle or other equipment without supervisor consent. 6. It shall be the Employee’s responsibility to practice good housekeeping methods to the extent possible. This will include the disposal of trash, keeping materials and supplies orderly, appropriately labeled, and stored safely, and keeping equipment and material from obstructing roads and walkways. 7. Employee shall operate vehicles in a responsible and safe manner on the job site and anytime they are on company property. Employee shall have a current and valid driver’s license and comply with all applicable local or state laws governing motor vehicle use. See Vehicle Policy. 8. The use of a hand held cellular telephone while operating a moving vehicle is not authorized by the Company. Employees involved in a motor vehicle accident while using a telephone in a moving vehicle will be subject to disciplinary action. Reporting Unsafe Conditions/Hazard Identification All Employees shall promptly report to the Area Production Manager, Safety Department and/or company Field Manager any unsafe condition or work practice. Anytime an unsafe condition or work practice is reported, immediate steps will be taken to correct the situation. The employee, Field and Area Production Manager will be responsible for assuring the reported condition or unsafe work practice is corrected immediately. The Field Production Manager, Area Production Manager and employee share the responsibility to make sure safe work conditions are maintained at the work site at all times. All personnel have the authority to suspend operations due to an unsafe condition. 6 Section 3 PERSONAL PROTECTIVE EQUIPMENT I. Purpose The purpose of this Personal Protective Equipment (PPE) Program is to protect employees from the risk of injury by creating a barrier against workplace hazards. PPE will be provided, used and maintained when it has been determined that its use is required and that such use will lessen the likelihood of occupational injury and/or illness. II. Scope The program applies to all employees required to wear PPE. This program addresses all forms of PPE except respiratory and hearing protection, which are addressed in separate sections. III. Responsibilities A. Responsible managers have the primary responsibility for implementation of the PPE program in their work area. Responsible managers will: a. Provide and make available appropriate PPE; b. Ensure and certify completion of a PPE assessment; c. Ensure employees are trained on the proper use, care and cleaning of PPE; d. Maintain records of training and PPE supplied; e. Supervise employees to ensure that the PPE program elements are followed and that employees properly use and care for PPE; f. Ensure that defective or damaged equipment is immediately removed from service; g. Ensure proper disposal and cleaning of contaminated PPE; and h. Designate a PPE coordinator to supervise the distribution, maintenance, and care of equipment. B. Employees are responsible for conforming to the requirements of this policy. Employees will: a. Wear PPE as necessary; b. Attend PPE training sessions; c. Care for, clean, maintain and dispose of PPE as necessary; and d. Report any damaged or defective PPE to their responsible manager. IV. Procedure A. Hazard Assessment a. Based on a general assessment of all routine work sites, it is Laramie policy that all employees will utilize safety glasses, safety footwear, hard hat and flame retardant clothing on all sites. Additional PPE may be required based on a hazard assessment. 7 b. At the start of any field activity, the employee will assess the need for specific PPE based on the job tasks and the PPE assessment. c. If during the course of field activities, a hazardous condition requiring the use of PPE, not addressed by the hazard assessment, the hazardous condition will promptly be addressed and appropriate PPE will be added before proceeding unless some action eliminates the hazard. B. General Requirements a. All PPE procured will be designed to meet relevant National Institute of Occupational Safety and Health (NIOSH), American National Standards Institute (ANSI) or other generally accepted industrial standards. b. Equipment will be maintained and worn in accordance with manufacturer’s specifications. c. Care will be taken to ensure that the correct size is selected. C. Eye and Face Protection a. Eye protection with side protection that meet the requirements of ANSI Z 87.1- 2010 (and must be marked as such) will be worn during field activities. Exceptions may be in offices, field dog houses, and enclosed vehicles. b. Wherever hazards exist that may require additional eye protection, goggles or face shields will be worn. c. Equipment fitted with appropriate filter lenses will be used to protect against light radiation. Tinted or shaded lenses are not filter lenses unless they are marked or identified as such. d. Eye and face protection must be visually inspected for damage prior to each use. e. Safety glasses will be provided to employees. Those employees who need prescription safety eyewear will be reimbursed to a maximum of $200 annually for prescription safety eyewear. The eye exam will be the responsibility of the employee through their personal health/vision insurance or by other means. D. Head Protection a. The use of hard hats is mandatory in field locations for personnel except for those in offices and while in enclosed vehicles. Hard hats must comply with ANSI Z89.1 – 2003. Type 1, Class “E” hard hats are required. b. Hard hats are to be adjusted and maintained in good condition per manufacturer’s specifications. Metal and fiberglass hard hats are not allowed. Shells and suspensions of hard hats should be routinely inspected to determine their condition. c. It is recommended that shells be replaced within 5 years and suspensions within 1 year unless inspection reveals defects prior to the expiration of these periods. 8 E. Foot Protection a. All employees must wear protective footwear that complies with ANSI Z-41-1999 or ASTM F2412-05 and F-2413-05) unless in offices, field dog houses, or enclosed vehicles. b. Footwear must extend above the ankle when worn by field personnel. c. Footwear must be visually inspected for damage prior to use. d. Sandals, canvas, cloth or tennis shoes are prohibited outside of offices or enclosed vehicles. e. Field and office employees required to attend field areas on a regular basis will reimbursed to a maximum of $160 annually. F. Hand Protection a. Hand protection will be worn to protect against specific hazards such as chemical exposure, electrical hazards, heat, cuts, bruises or abrasion. b. Refer to SDS and Hazard Assessments to aid in the selection of appropriate hand protection for the job tasks. c. Gloves with excessive wear or damage shall be replaced immediately. G. Protective Clothing a. Company field employees and contractors are required to wear long sleeved shirts and full-length pants. Tank tops, sleeveless shirts and shorts are prohibited. Loose fitting clothing shall not be worn in areas where it could be caught in rotating equipment. b. The outermost layer of clothing while on field locations must be FR (flame retardant) and meet the requirements of NFPA 2112-2012. c. Because synthetic fiber is known to melt under high temperature conditions, it is recommended that cotton or natural fiber clothing be worn under FR garments. d. All FR clothing should be cared for per manufacturer’s recommendations per NFPA 2113. Torn or ragged FR clothing will be replaced. e. When working on or near a roadway, a reflective or highly visible warning vest should be worn. f. FR clothing will be provided to the employee on an as-needed basis. H. Portable gas detectors a. Gas detectors used for detecting contaminants in the breathing zone and those used for hot work or confined space entry must be calibrated and maintained to the manufacturer’s instructions and made to read zero in fresh air before use. I. Hearing Protection 9 a. Hearing protection will be required at areas with noise levels at 85 db(A) or higher. At noise levels above 100 db(A), it is recommended that double hearing protection (muffs and plugs) be used. b. High noise areas will be posted with warning signs. These areas will be periodically surveyed for noise level changes that may generate the need for a Hearing Conservation Program. c. Employees must be aware of the possibility that a high noise level area may be encountered that has no posting and must be prepared at all times to don hearing protection if needed. J. Respiratory Protection a. Respiratory protection is required anytime employees may be exposed to airborne hazards such as dusts, vapors, fumes, sprays, etc. b. Refer to the chemical’s Safety Data Sheet (SDS) prior to working with chemicals and follow all directives in the use of specialized PPE. c. At the time of this assessment, employees are not subjected to chemicals or routine work environments that require specialized respiratory protection. Employees should understand the Respiratory Protection procedure to an awareness level only. If changes in the workplace present respiratory hazards that require the employee use of respiratory protection, a Respiratory Protection Plan will be required. K. Training a. PPE training will include the following elements; i. When PPE is necessary; ii. What PPE is necessary; iii. How to properly don, doff, and adjust PPE; iv. Limitations of PPE; and v. Care, maintenance, disposal, and useful life of PPE. b. Employees will be expected to understand how to use PPE properly before they are allowed to perform work that requires the use of PPE. c. Retraining is required when: i. There are indications that PPE is not being used properly; or ii. There are changes in the PPE policy or equipment. L. Recordkeeping a. Written records will be kept of the names of persons trained, the type of training provided, and the dates when training occurred. b. All training records will be maintained at the field office for at least five years. c. PPE assessments by category and PPE hazard assessment certification will be maintained at the field office. 10 V. Revision History The table below lists all changes made to this section since the implementation of the program: VI. Supporting Documents A. PPE Assessment B. PPE Certification C. Glove Chart 11 Section 4 VEHICULAR OPERATIONS I. Purpose The purpose of this Vehicular Operations section is to establish a policy for usage of vehicles owned or leased by Laramie Energy. The following policy is designed to ensure that drivers who are assigned owned or leased vehicles (referred to as Company vehicles and may include any company-owned or company-leased automobiles, vans, four-wheel drive vehicles, pickup trucks, SUVs, etc.) do so safely and in accordance with company policies and applicable motor vehicle laws. II. Scope This policy is applicable to all employees or contractors who are assigned or use Company vehicles. III. Responsibilities A. Management – Responsible for the overall implementation and usage of this policy throughout the field. B. Safety Department – Responsible for applicable training and providing equipment to ensure safe vehicle operation. IV. Procedure A. Use – Company vehicles will always be used in accordance with good judgement and in compliance with all local, state and federal traffic laws and according to the nature of the job. Specific requirements include the following: a. Personal use for all Company vehicles is prohibited (except as stipulated in section C). b. Driving Company vehicles on vacation or personal trips is prohibited. c. Company vehicles will only be driven by employees or designated contractors. d. Laramie Energy reserves the right to monitor company vehicle use, at any time, with or without the employee’s knowledge and as permitted by state law. This includes and is not limited to the use of GPS devices, or other electronic surveillance devices. Data monitored may include but is not limited to vehicle location, speed and distance travelled. e. Any Laramie employee whose operating license or privileges have expired or have been suspended or revoked must notify their supervisor immediately. Operating or using a Company vehicle or a personal vehicle for company business under an expired, suspended or revoked license is a violation of this policy. Laramie Energy reserves the right to use driving record review services to 12 review current operating licensure and driving records of company employees who are assigned a Company vehicle. f. Regardless of severity, any accidents, collisions or damage involving a Company vehicle, or injury resulting from a Company vehicle accident, require immediate supervisor and safety department notification and subsequent incident report (any loss or damage to a rental vehicle should be reported in accordance with the rental agreement). Registration and insurance information is located in each Company vehicle. g. Laramie Energy reserves the right to revoke Company vehicle driving privileges at management’s discretion upon violation of this policy and/or a demonstrated pattern of unsafe driving practices. Employees in violation of this policy shall also be subject to disciplinary actions up to and including termination. B. Company Vehicle Driver’s Responsibility a. It is the assigned driver’s responsibility that the assigned vehicle is kept in safe and dependable operating condition and as clean as working condition will reasonably permit. b. Use of seat belts in Company vehicles or personal vehicles driven for company business is required at all times. The driver is responsible for ensuring that all passengers are wearing seat belts prior to putting the Company vehicle into motion. c. Any tickets issued for a traffic infraction, moving or non-moving, while driving or using a Company vehicle must be reported to the employee’s supervisor as soon as reasonably possible. Fines associated with any traffic infraction are the responsibility of the employee. d. Engaging in distracting activities while driving a Company vehicle is prohibited and includes cell phone usage, unless such usage is hands-free. The use of a mobile phone or other mobile communications device while driving a Company vehicle must comply with current local and state law. e. Transporting firearms is strictly prohibited in all Company vehicles. An exception may be made with supervisor approval. f. Employees, prior to being assigned a Company vehicle, must present a valid driver’s license. g. Smoking is prohibited in Company vehicles. C. Company Vehicle Personal Use a. Examples of permitted personal use include: i. Stopping to run an errand directly on the way to or from work, ii. Going to/from a business related function, iii. Meals during the workday, or iv. Responding to an emergency. b. Examples of prohibited personal use include: i. Running personal errands (except for permitted use detailed in C.a.i) 13 ii. Use of a Company vehicle for non-business related activities (such as camping, fishing, boating, golfing, vacationing, hauling, etc.) iii. Any other non-business related use. V. Revision History The table below lists all changes made to this section since the implementation of the program: 9.28.16 adm LL VI. Supporting documents A. Monthly inspection checklist B. Statement of Compliance & Acknowledgment of Responsibilities 14 Section 5 WALKING AND WORKING SURFACES I. Purpose This program is intended to protect workers from potential health and safety hazards encountered with walking/working surfaces in the office and in the field. II. Scope All employees and contractors will comply with the requirements of this section. Only trained and authorized workers will be allowed to access ladders and other appropriate working surfaces. Employees will exercise professional judgment and limit their exposures to the absolute minimum. III. Definitions Definitions applicable to walking and working surfaces can be found in 20CFR 1910.21. IV. Responsibilities A. Managers are responsible for: a. Ensuring training is completed for all office, administrative, and field employees on the procedures in this section. b. Providing proper tools and equipment to ensure that the procedures are followed. c. Ensuring reported unsafe conditions are corrected. B. Employees are responsible for: a. Reporting all safety problems immediately to their supervisor. b. Maintaining a neat and sanitary office environment. c. Following all safety and health policies. V. Procedures A. Keep all worker areas, aisles, and passageways, including stairs, doorways, electrical panels and exits, free and clear of obstructions, and maintain them in a clean, orderly, and sanitary fashion. B. Maintain floors and stairs in a clean and dry condition (so far as possible). If a spill occurs, clean it up immediately or warn others and report it so that it can be cleaned up. C. All trip hazards must be eliminated. Common hazards include unsecured rugs, cords in walking areas, and projecting electrical outlet boxes. 15 D. Step stools, if equipped with wheels, should have an automatically locking base or wheel locks. Inspect to ensure all parts are secure and safety features, such as wheel locks and anti-slip treads, are intact and properly functioning. E. Ladders 1. Ladders will be selected for the work intended. 2. Make sure the ladder is the proper height for the job. Extension ladders will be at least 3 feet taller than the point of support and stepladders will be selected so that the worker is never required to use the top two steps. 3. Inspect ladders before use. Defective ladders will not be used. Some signs of defects include: broken rungs, split side rails, worn or broken safety feet, broken hinges and spreaders, loose nuts, bolds and/or rivets. If defective, remove ladder from service and place a warning tag reading on it “DO NOT USE.” 4. When using a straight ladder, place feet on a firm surface and secure it at the top so that it cannot slide sideways. 5. Always face the ladder when climbing or descending. Use both hands – never carry anything in your hands. You have climbed too high if your knees are above the top of the ladder or you cannot maintain a handhold on the ladder. 6. There should only be one person on a ladder at a time unless designed for multiple users. 7. Do not use metal ladders if there is a possibility of contact with electrical conductors. 8. Never use a stepladder as a straight ladder. 9. Do not use stepladders as a brace or support for a work platform or a plank. 10. Never lean from the side of a ladder. If necessary, the task will be evaluated for potential fall hazards. Other alternative solutions will be used to allow a safe approach to the task. F. Stairs, ramps and walkways will be clear and in good condition. Always use the handrail provided when ascending or descending stairs. G. Employees will be cautioned to watch for holes, concrete dividers, curbs, discarded items, paper and other tripping hazards. H. During cold weather, employees will be cautioned about icy conditions on walkways and parking lots. 16 I. Floors holes and openings will be protected by a cover or standard railing. Should the cover or railing need to be removed, the floor opening or hole will be constantly attended by an attendant assigned to warn others of the hazard. J. Open-sided floors or platforms that are four or more feet above ground level will be provided with proper standard railing. When there is equipment that could fall from these elevations, the installation of a standard toe board is required. K. Scaffolds – there are several different types of scaffolds. Access to elevated locations or work at heights requires guardrails, fall protection, or a personal fall arrest system device. Employees will be cautioned that if the work cannot be performed from the ground or by another available means, the following general requirements for scaffolding must be met: 1. Scaffolds will be used only when work cannot be performed from the ground or from solid construction. 2. Footing or anchorage for scaffolds will be sound, rigid, and capable or carrying the intended load without settling or displacement. Unstable objects, including barrels, boxes, loose bricks or concrete blocks, will not be used to support scaffolds or planks. The use of base plates and mudsills is acceptable. 3. Access to the scaffold must be provided by a ladder, ramp, or other safe means. Never use the side frames to access the scaffold. 4. Scaffolds must be fully planked. The planks will not extend less than six inches and not more than 18 inches from the end. 5. Scaffolds will not be used during storms, high wind, or when covered by ice or snow. 6. Scaffolds, over 10 feet from ground level, must have standards guardrails, toe boards, and will be properly cross-braced. 7. Mobile ladder stands and scaffolds will have positive wheel and/or swivel lock casters to prevent movement. VI. Revision History The table below lists all changes made to this section since the implementation of the program: 17 Section 6 HAZARD COMMUNICATION I. Purpose It is Laramie Energy’s policy to comply with the requirements of OSHA’s Hazard Communication Standard (29 CFR 1910.1200) and the UN Globally Harmonization System of Classification and Labelling of Chemicals (GHS) and to ensure that the hazards of all chemicals are properly evaluated and that the information is available to all personnel in the workplace. II. Scope This program applies to all work operations where there is exposure to hazardous chemicals that are known to be present in the workplace in such a manner that employees may be exposed under normal conditions or use in a foreseeable emergency. The mere presence of a hazardous chemical in the workplace does not trigger coverage under the HCS. There must be actual or potential exposure to an employee. Consumer products are not covered by this program to the extent that the use of the products results in a duration and frequency of exposure that is not greater than that which could be reasonably experienced by consumers. III. Responsibilities A. Safety Department – to be responsible for implementing program, training employees on requirements and hazards, and provide training documentation upon request. B. Operations Management – a. To hold contractors accountable for providing Safety Data Sheets (SDS) for each hazardous material they bring onto a Company site and the containers in which chemicals are brought on location to comply with all applicable DOT regulations and labeling requirements. b. To identify chemical hazards and to communicate chemical hazard information to onsite employees and to evaluate and provide appropriate PPE for the job. C. Employees – to ensure that all recommended and appropriate precautions specified on the SDS and by the onsite supervisor are implemented and adhered to when working with hazardous chemicals. D. Contractors – to provide SDS’s for each hazardous material they bring onto company property and have all containers labelled to meet all regulations and to ensure that training is conducted for all their employees as specified in 29CFR 1910.1200. IV. Procedure A. Common hazardous chemicals a. A list will be maintained of all hazardous chemicals used in the field and updated as necessary. 18 b. This list will identify the corresponding Safety Data Sheet (SDS) for each chemical. B. Safety Data Sheets a. A copy of a SDS for every substance on the list of hazardous chemicals in the field will be maintained. b. SDS’s for all hazardous chemicals used in the field will be readily accessible to employees at all times. c. If a hazardous chemical is ordered and/or used, the order is to include a request for the SDS. All SDS’s will be reviewed for content and completeness. d. SDS’s of new substances to be purchased must be reviewed and the chemical approved for use by a manager or designee. Whenever possible, the least hazardous substance will be obtained. C. Warning Labels a. All containers of hazardous chemicals will be properly labelled. b. All labels will identify the hazardous chemical and the appropriate hazard warning, including the target organ effects. c. Each label will be checked with the corresponding SDS to verify the information. d. Alternate labeling provisions, such as tags or markings, may be made for containers that are of unusual shape or size and do not easily accommodate a legible label. e. Chemicals that are transferred from a properly labeled container to a portable container, and that are intended only for the immediate use of the person who performs the transfer are not required to be labeled. Immediate use is defined in 29 CFR 1910.1200. D. Training a. Each employee who is potentially exposed to hazardous chemicals will receive training as outlined below. b. New employees will receive training on the contents of this program and specific training on the chemicals that the individual will be directly working with during orientation and prior to performing work where exposure may occur. c. Additional training will be provided for employees whenever a new chemical is introduced into their work area. d. As warranted, training may be provided based on the uniqueness of the hazards to be encountered at a worksite. e. The training program will emphasize the following elements: i. A summary of the Hazardous Communication Standard and the written program; ii. Hazardous chemical properties, including visual appearance and odor, and methods that can be used to detect the presence or release of hazardous chemicals; 19 iii. Physical and health hazards associated with potential exposure to hazardous chemicals; iv. Procedures to protect against hazards, such as personal protective equipment, work practices, and emergency procedures; v. Hazardous chemical spill and leak procedures; and, vi. Location of SDSs, how to understand their content, and how employees may obtain and use appropriate hazard information. E. Contractors a. Outside contractors will be advised of any chemical hazards that may be encountered in the normal course of their work. b. Outside contractors will be notified of the location and availability of SDSs. c. Each contractor bringing chemicals on-site must provide the appropriate hazard information, including SDSs. All containers of hazardous chemicals brought on- site by an outside contractor must be properly labeled. F. Non-routine tasks – if a non-routine task is planned, affected employees must be informed of any chemical hazards associated with the performance of the task(s) and appropriate measures before such work is initiated. V. Revision History The table below lists all changes made to this section since the implementation of the program: 20 Section 7 CONTROL OF HAZARDOUS ENERGY SOURCES I. Purpose The purpose of this program is to protect against the inadvertent or unintended release of energy, movement, or flow in electrical, mechanical, or material systems, which could result in injury to workers. Lockout of these systems must be utilized, where needed, to safely allow entrance into or close contact with equipment. These procedures will be used to ensure that machines or equipment being attended to are isolated from all potentially hazardous energy and locked out before employees perform any activity where unexpected energizing, start up, or release of stored energy could cause injury. II. Scope All employees will comply with the requirements of this program. Only authorized employees may apply locks and tags and only in accordance with this program. Compliance with 29 CFR 1910.147, 1910.269, and 1910.333 will be adhered to at all times. III. Definitions Affected employee. An employee whose job requires him or her to operate or use a machine or equipment on which servicing or maintenance is being performed under LOTO or whose job requires him or her to work in an area in which such servicing or maintenance is being performed. Affected or authorized employees may disable, shut down, or turn off machines or equipment. Affected employees are not authorized to lock or tag out systems or equipment. Authorized employee. A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment, which has a source(s) of energy that can cause injury. Furthermore, any employee who implements a lockout or tagout procedural element on machines or equipment (for servicing or maintenance purposes) is considered an authorized employee. This includes employees who: perform energy isolation, implement LOTO, dissipate stored energy, verify energy isolation, implement actions to release LOTO, and test or position machines or equipment. Capable of being locked out. An energy isolating device is capable of being locked out if it has a hap or other means of attachment to which, or through which, a lock can be affixed, or it has a locking mechanism built into it. Other energy isolating devices are capable of being locked out, if lockout can be achieved without the need to dismantle, rebuild, or replace the energy- isolating device or permanently alter its energy control capability. Energized. Connected to an energy source or containing residual or stored energy. Conductors and parts of electrical equipment that have been de-energized, but have not been locked and tagged out in accordance with 1910.333, must be treated as energized parts. Conductors and 21 parts of electrical equipment that have been de-energized under procedures other than those required by 1910.269 must be treated as energized. Energy Isolation Device. A mechanical device that physically prevents the transmission or release of energy, including but not limited to manually operated circuit breakers, disconnect switches, line valves, block and any other similar devices. Push buttons, selector switches and other control circuits are not acceptable as energy isolation devices. Lockout Device. A device that utilizes a positive means, such as a key and lock, to hold an energy isolating device in a safe position and prevent the energizing of a machine or equipment. Each lockout device will be supplied with a tag meeting the requirements of 1910.147 and 1910.333 and identifying the lock user and the date of application. Servicing or Maintenance. Workplace activities, such as constructing, installing, setting up, adjusting, and inspecting machines or equipment. These activities include lubrication, cleaning, or un-jamming machines or equipment and making adjustments. They may also include non- exempt tool changes when the employee may be exposed to the unexpected energization, start-up, or release of hazardous energy. Tagout Device. A prominent warning device, such as a tag, and a means of attachment, that can be securely fastened to an energy isolating device in accordance with an established procedure to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed. If an item is capable of being locked out, it must be. IV. Responsibilities A. Responsible managers will ensure: a. Implementation of the program within the field operations. b. Employees are trained on program and specific procedures where needed. c. Adequate resources are provided to support the program. B. Employees (including authorized and affected) are responsible for: a. Attending training and demonstrating proficiency where appropriate. b. Following the program and procedures and incorporating their requirements into the work tasks. c. Informing the company when hazards or inadequacies are found. d. Ensuring designated contractors have a program in place, adhere to the program, and have had training. e. Ensure that all needed equipment and supplies are ready and available. f. Ensure that appropriate documentation is completed. g. Participate in periodic inspections of the program when requested to do so. 22 V. Procedures All work involving isolation of hazardous energy will be done in accordance with 29 CFR 1910.147 – The control of hazardous energy (lockout/tagout). A. Preparation for Lockout/Tagout. Before working on, repairing, adjusting or replacing machinery and equipment, the following procedures will be utilized to place the machinery and equipment in a neutral or zero mechanical state. Before authorized or affected employees turn off a machine or piece of equipment, the authorized employee will have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the means to control the energy. If there is any question about how to implement a lockout/tagout it should be reviewed with the production manager. B. Notification of Employees. Affected employees shall be notified by the authorized employee of the application and removal of lockout/tagout devices, and the prohibition regarding attempts to restart or reenergize equipment which is locked/tagged out. C. Preparation for Shutdown. Affected employees should assist the authorized employees before shutting down equipment, such that the authorized employees shall know the types, magnitude and hazards of the energy to be controlled along with the methods to control the energy. D. Shutting down the equipment. An orderly shutdown must be utilized to avoid any additional or increased hazards to employees. Established equipment shutdown procedures for the machine or equipment should be followed to turn off or shut down the machine. E. Equipment isolation. All energy isolating devices that are needed to control the energy shall be physically located and operated as appropriate, to isolate the equipment from the energy source. F. Applying the Lockout/Tagout Device. Lockout/Tagout devices shall be affixed to each energy isolating device by an authorized employee. A lock and/or tag shall be affixed to the energy isolation device. For clarification purposes, this means that if the energy isolation device is capable of being “locked”, then a lock and tag will be affixed. If an energy isolation cannot be locked, then a tag only will be affixed – but must be treated as equal integrity as a lock. No lock shall be affixed without a tag stating who locked out the equipment, the reason for the lockout/tagout, the date, and the appropriate warning tag, such as “Danger Do Not Operate”. Where a tag cannot be affixed directly to the energy isolating device, the tag shall be located as closely and safely possible to the device, in a position that will be immediately obvious to anyone attempting to operate the equipment. Where tagout devices are used with energy isolating devices designed with the capability of being locked, the tag attachment shall be fastened at the same point at which the lock would have been attached. 23 G. Releasing Stored or Residual Energy. All potentially hazardous stored or residual energy shall be relieved, disconnected, restrained and equipment otherwise rendered safe. Stored energy (capacitors, springs, elevated members, rotating flywheels, and hydraulic/gas/air/steam systems) must be relieved or restrained by grounding, repositioning, blocking, and/or bleeding the system. If there is a possibility of re- accumulation of this energy, the verification of isolation must be continued until the job is complete of the possibility of accumulation no longer exists. H. Verifying Isolation (try out). The authorized employee shall verify that isolation and de- energization of the equipment has been accomplished prior to starting work on the locked or tagged out equipment. After ensuring that no personnel are exposed, operate/test (try out) the starting mechanism to make certain the equipment will not operate by following the normal startup procedures (depress start button, etc.) NOTE: Be certain to return the switch or START button, which was used to test the lockout, to its OFF or NEUTRAL position. At the beginning of each shift, or after any substantial absence from the job (breaks or meals), any person who has equipment locked out will check the equipment and the disconnecting device to determine and verify that all equipment is still safe for work and has not been returned to service during their absence. I. Release from Lockout/Tagout. Before energy is restored to the equipment the following steps shall be completed by the authorized employee: a. Assure that the equipment is ready to be energized and operated. The authorized employee should ensure that all nonessential items have been removed and the equipment is operationally intact (i.e. machine guards). b. Notify all affected employees that LOTO devices are being removed and ensure that all employees are in a safe position, away from the equipment and that they are to remain clear of the equipment while it is being re-energized. Re-energize the machine according to the associated procedure. Verify the machine is operating normally and safely before allowing a resumption of work in the machine’s vicinity. If the authorized employee is unavailable, the following necessary steps are required: c. Obtain approval of the Production Manager or designee for removal of lockout/tagout devices after completing the Lock Removal Form. d. Confirm that the authorized employee is not at the facility/location and unavailable to remove his or her personal lockout/tagout device. Confirm that the lockout/tagout is no longer required. Make a reasonable effort to contact the authorized employee whose lockout/tagout device is on the equipment that his or her LOTO device is to be removed. Remove the lockout/tagout device using bolt cutters or equivalent means. 24 e. Notify the authorized employee, whose lockout/tagout device has been removed, of the removal of his or her LOTO device before he or she returns to work at the facility/location. VI. Additional Guidelines A. Personal Lockout/Tagout. When only a few isolation devices need LOTO and/or only a few personnel are involved with the LOTO, then in most cases a lockbox is not needed for LOTO. In personal LOTO, each authorized employee will place his or her lock and/or tag on the energy isolation device and utilize a tracking form for documentation. The authorized employee makes the decision on which method is most appropriate. B. Group Lockout/Tagout. Each contract company must designate the primary authorized employee to conduct the verification process and ascertain the exposure status of individual group members and take the steps needed to afford the employees in their crew, craft, department or group the level of protection equivalent to that provided by the implementation of personal LOTO devices. Each authorized employee has the right, and must be given the opportunity to participate in the verification process and apply their LOTO device should they so decide. *Note: if the contracting company has a more stringent LOTO program, it’s program may be followed. C. Tagout. Devices shall warn against hazardous conditions if the machine or equipment is energized. Tags may say “Do Not Start”, “Do Not Open”, “Do Not Close”, “Do Not Energize”, “Do Not Operate”, etc. Long term isolations or Out of Service tags may also be applied where appropriate. The primary authorized employee will decide which tag(s) will be used. D. Extended Lockout/Tagout. When equipment needs to be locked and/or tagged out for more than one work shift or workday, these LOTO’s must be communicated to personnel and contractors at the location/facility. If other employees are assigned to work on the affected equipment during this period, they will add their lockout/tagout devices and remove them upon completion of their tasks. E. Exclusive Control. Where the equipment or system is under the exclusive control of the employee (i.e. some pigging operations, orifice plate changes, dropping soap sticks, etc.), LOTO may not be needed. Under this exemption, a worker must be in physical control of all energy sources that may create a hazard and provide a safe level of control. F. Contractors. When it becomes necessary for a contractor to perform LOTO, the contractor will inform the Laramie representative of the LOTO plan and procedure and receive approval for the job. It will be at this time that the Laramie representative will determine if a Laramie representative will need to be present during the LOTO activity being performed. When performing group LOTO, all contractors must provide their own personal locks and tags. G. Shift or Personnel Changes. Employees involved in LOTO will ensure the continuity of lockout/tagout protection, including provision for the orderly transfer of lockout/tagout 25 device protection between off-going and oncoming employees. This is required to minimize exposure to the hazards from the unexpected energization or startup of the machine or equipment, or release of stored energy. VI. Revision History The table below lists all changes made to this section since the implementation of the program: VII. Appendices A. LOTO Tracking Form B. Lock Removal Form C. LOTO Observation Form D. Annual Certification 26 Section 8 PERMIT REQUIRED CONFINED SPACES I. Purpose The objective of the Permit Required Confined Space portion is to protect employees from confined space hazards during the performance of operations and maintenance duties. II. Scope This section addresses and establishes procedures for the control and permit for entry of Confined Spaces. This procedure applies to all operating areas and facilities when Confined Space activities are performed. III. Definitions E. Authorized entrant. An employee who has been approved to enter the confined space by an appropriate manager/supervisor. F. Attendant. An individual stationed outside one or more permit spaces that monitors the authorized entrants and who performs all attendants’ duties as described in 29CFR1910.146. G. Confined Space. A space that: a. Is large enough and so configured that an employee can bodily enter and perform assigned work; and b. Has limited or restricted means for entry or exit (for example, tanks, vessels, vaults, and pits are spaces that may have limited means of entry); and c. Is not designed for continuous employee occupancy. H. Permit Required Confined Space (permit space). A confined space that has one or more of the following characteristics: a. Contains or has a potential to contain a hazardous atmosphere (as defined in 29CFR1910.146(b)); or b. Contains a material that has the potential for engulfing an entrant; or c. 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 d. Contains any other recognized serious safety or health hazard. IV. Responsibilities G. Company Oversight a. Managers are responsible for: i. Ensuring that employees understand the requirements of the Permit Required Confined Space Entry Program and that they have the 27 knowledge and skills required for the safe entry, if necessary, into permit- required confined spaces. ii. Complying with all requirements of the Permit Required Confined Space Entry Program. b. Employees are responsible for complying with all requirements of the Permit Required Confined Space Entry Program. H. Confined Space Entry Team Roles and Responsibilities a. Authorized Entrants and their Duties. The employer shall ensure that each authorized entrant: i. Knows the hazards that may be presented during entry, including information on how exposure might occur, signs and symptoms of exposure, and their consequences; ii. Is properly trained in permit required confined space entry procedures; iii. Knows how to properly use the equipment associated with confined space entry (testing, monitoring, communicating, etc.) iv. Communicates with the attendant as necessary to enable the attendant to monitor entrant status in the space and alert him of the need to evacuate. v. Alerts the attendant whenever an entrant recognizes any warning sign or symptom of exposure to a dangerous situation or detects a prohibited condition; vi. Exit from the permit space as quickly as possible whenever: 1. An order is given to evacuate, 2. The entrant recognizes any warning sign or symptom of exposure to a dangerous condition, 3. The entrant detects a prohibited condition, or, 4. An evacuation alarm is activated. b. Authorized Attendants and their duties. The employer shall ensure that each authorized attendant: i. Knows the hazards that may be faced during entry including information on the mode, signs or symptoms, and consequences of the exposure; ii. Is aware of possible behavioral effects of hazard exposure to authorized entrants; iii. Continually maintains an accurate count of authorized personnel in the permit space; iv. Remains outside the permit space until relieved by another attendant; v. Communicates with authorized personnel as necessary to monitor entrant status and to alert them of the need to evacuate the space; vi. Monitors activities inside and outside the space to determine if it is safe to remain in the space and orders the authorized entrants to evacuate the permit space immediately under any of the following conditions; 28 1. If the attendant detects a prohibited condition; 2. If the attendant detects and behavioral effects of a hazardous exposure in authorized entrant; 3. If the attendant detects a situation outside the space that could endanger the entrants; or 4. If the attendant becomes unable to effectively and safely perform all the duties required of him. vii. Summon rescue and other emergency services as soon as the attendant determines that authorized personnel may need assistance to escape from permit space hazards; viii. Takes the following actions when unauthorized persons’ approach or enter a permit space while entry is underway: 1. Warn the unauthorized persons that they must stay away from the permit space; 2. Advise the unauthorized persons that they must exit immediately if they have entered the permit space; and 3. Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space. ix. Perform non-entry rescue as specified by the employer rescue procedure if applicable. x. Perform no duties that might interfere with the attendant’s primary duty to monitor and protect the authorized entrants. c. Entry Supervisor Duties. The employer shall ensure that each authorized entry supervisor: i. Knows the hazards that may be presented during entry, including information on the mode, signs or symptoms, and consequences of the exposure; ii. Verifies that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin; iii. Verifies that all persons involved in permit entry are properly trained and competent in their assigned duties; iv. Verifies that rescue services are available and that the means for summoning them are operable; v. Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations; vi. Determines, whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards and operations performed within the space, that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained; and, 29 vii. Terminates the entry and cancels the permit when the entry operations specified by the permit have been completed or when a condition not allowed under the entry permit arises in or near the permit space. (Note: Entries conducted under permitted conditions will require a minimum of three personnel: entry supervisor, entrant, and attendant plus provisions for rescue and emergency services personnel.) V. Procedures A. General. Laramie prohibits employees from entering permit spaces without the written approval of a manager. This includes permit spaces that have been reclassified or are being entered under alternative procedures as specified in 1910.146(c)(5)(ii) and (c)(7). The final determination of whether a confined space is a permit-required confined space shall be made by the employee who will be the entrant with the concurrence of their manager. If entry must take place, the guidelines below shall be employed. B. Entry Requirements. No entry will be permitted unless all the provisions of the 1910.146 standard have been met and the safety department has been consulted. Only employees who are trained in confined space entry and are medically fit to wear the necessary personal protective equipment may enter permit-required confined spaces. C. Evaluations. The Safety Department will conduct an initial evaluation on any known confined spaces and place these spaces into the Confined Space Inventory with a determination of permit requirements. In the event that a space needs to have entry (i.e. tank cleaning, valve repair, internal inspections, etc.), an additional evaluation will be completed by a trained person prior to entry. Employees, in coordination with managers, will evaluate the hazards identified by the employer which are present in the permit-required confined space. In addition, the space will be independently evaluated by the employee for any other hazards which may be present. D. PPE. In addition to personal protective equipment normally worn by employees, an employee who is conducting inspections involving entry into a permit-required confined space will be provided with and use all personal protective equipment necessary for safe entry. A self-contained escape respirator shall be worn where confined spaces have the potential to develop hazardous atmospheres. E. Attendant. A second trained employee will act as an attendant when the first employee enters the permit space. Both employees will be cross-trained in each other’s duties as an entrant and an attendant. The attendant will not enter the confined space under any circumstance. The attendant will monitor the activities in the confined space and order the entrant to evacuate if there are changes that could present a hazard. 30 F. Rescue. A safe means of rescue will be readily available on site. The attendant will not perform rescue. The attendant will confirm that personnel designated to perform rescue have been trained in accordance with 1910.146(k). If lockout is necessary to control hazards within the confined space, the entrant will follow lockout procedures. G. Conditions. The employee who will enter the confined space may use the permit entry procedures established by the employer only if all the following conditions are met: 1. The employer has a permit required confined space entry program that complies with 1910.146. 2. All hazards and potential hazards have been identified. There are no discrepancies or potential discrepancies between the employer’s assessment of the hazards and the assessment conducted by the employee. 3. The entrant verifies all entries on the permit and assures that all hazards or potential hazards have been eliminated or controlled. 4. The entrant will conduct his/her own atmospheric monitoring to confirm the space is safe to enter. H. Permit. A copy of the entry permit or certification will be given to the responsible manager for signature. Entry will not begin until a signed copy has been returned to the entrant. The permit must also be signed by the entry supervisor. The entry permit will be terminated by the responsible manager if entry conditions change or when the entry has been completed. I. Recordkeeping. Entry permits and certifications will be delivered to and be maintained in the safety department upon completion. The retention period for permits is 12 months. VI. Training A. Initial confined space entry awareness training for field employees. B. Initial site-specific permit-required confined space entry procedures and the confined space entry permit for affected personnel. C. Employees who are subject to a Confined Space Program and will be doing entry or attendance duties must comply with all training requirements as determined by the program. 31 VII. Revision History The table below lists all changes made to this section since the implementation of the program: 32 Section 9 FIRST AID/CPR/BBP FIRST AID/CPR/BBP I. Purpose II. Scope III. Definitions IV. Responsibilities V. Procedures a. Assessment b. Contractor injury c. Designated FA responder d. Administration of first aid reporting e. Exposure Control Plan i. Exposure Determination ii. Hazard Assessment iii. Method of implementation and Control iv. Hep B vaccination v. Post exposure vi. Recordkeeping VI. Training VII. First Aid Equipment VIII. Revision History IX. Supporting documents (Hep B vaccination) Incidents and First Aid Emergency phone numbers are maintained in all field vehicles. 1. In cases of emergency at remote drilling locations, Table 1 of the site-specific Emergency Action Plan will provide the appropriate emergency phone numbers. 2. If the emergency is at the corporate offices, call 911. State your name, the nature of the emergency, and the exact location of the injured person or emergency. Answer all questions completely. DO NOT use 911 for routine calls to police or fire departments. Any incident that requires notification of the emergency response system must be reported to the Laramie Energy Production Manager (PM) and the Vice President of Operations (VPO). The emergency contacts are located in your Emergency Notification Chart. Laramie Energy’s general policies addressing incidents and first aid are listed below: 1. Laramie Energy shall be responsible for providing approved first-aid supplies and first aid trained personnel on the job as required by 29 CFR 1910.151. Trained personnel and supplies must be sufficient and suitable for the job. 33 2. The Employee shall promptly report to Laramie Energy’s PM and VPO all incidents and occupational injuries or illnesses. Following an occupational injury or illness, the Employee shall furnish to Laramie Energy copies of all applicable workers’ compensation first report of injury forms so that Laramie Energy can revise the OSHA 200 log. The report shown in Attachment 1 (On The Job Injury or Accident Report) shall be completed and forwarded to the PM within 24 hours. 3. Laramie Energy shall investigate all incidents involving Employees that result in an OSHA recordable injury, spill/release to the environment, fire/explosion or damages in excess of $500. 4. Pursuant to Laramie Energy’s Drug and Alcohol programs, post-accident drug and alcohol tests may be conducted for any accident or injury. First Aid Kits First-aid kits and required contents shall be maintained in a serviceable condition as required by 29 CFR 1910.151. Unit-type kits have all items in the first-aid kit individually wrapped, sealed, and packaged in comparable sized packages. Drilling/Completion Rig Supervisors as well as the Production Manager will maintain first aid kits on site at their operations trailers and in their vehicles. 34 Sec 10 FALL PROTECTION I. Purpose The Fall Protection section is designed to protect employees against the hazards related to falls. Fall protection systems will be utilized whenever a fall exposure may exist. II. Scope All employees will comply with the requirements of this section. Only trained and authorized employees will be allowed to utilize fall protection systems. Employees who are trained and authorized will follow all applicable procedures and requirements. III. Definitions Definitions applicable to fall related devices can be found in Subpart M of the OSHA standards and ANSI A10.14-1991. IV. Responsibilities C. Responsible managers have the primary responsibility for fall protection in their work area. Responsible managers will: a. Ensure that employees understand the purpose of OSHA’s Fall Protection Program; b. Ensure that employees avoid all unexpected exposures to fall hazards; c. Provide the components needed for the particular fall protection system to be utilized; and, d. Ensure that employees have the knowledge and skills required for the safe application and use of fall protection systems. D. Employees will follow the requirements of this section. V. Procedure A. Hazard Identification a. Effectively managing working at heights begins with identifying fall hazards in the workplace. Workers shall evaluate and control fall hazards. b. Examples of situations where a fall hazard exists include, but are not limited to, the following: 1. Unprotected sides and edges on walkways 4 feet or above; 2. Ramps, runways, and other walkways; 3. Wall openings; 4. Open top vessels or tanks; 5. Hoist areas; 6. Man lifts or powered platforms (at any height); 35 7. Crane baskets; 8. Personnel lifts; 9. Ladders, where three points of contact cannot be maintained; and 10. Derricks and masts. B. Hazard Assessment a. Where fall exposures are encountered on a work site, employees will assess the fall protection system(s) availability and applicability. The assessment will include any ladders, fixed and portable. b. Employees will only utilize the proper fall protection in accordance with OSHA requirements. c. Attention must be paid to whether a personal fall restraint system (PFRS) or a personal fall arrest system (PFAS) is needed. 1. A fall restraint system prevents an employee from falling any distance at all. The anchor of a fall restraint system is not called upon to withstand the force of an arrested fall, it only has to withstand the force of restraining a worker from moving further than the length of the lanyard. The anchor point must support a 3,000 pound load or have a safety factor of two. 2. A fall protection system arrests a person’s fall. 3. Fall restraint is preferred over fall arrest. C. Fall Prevention a. Fall prevention systems must always be used as the primary method of working safety at heights. If fall prevention systems are not practical, then fall protection systems must be used. Fall prevention consists of using engineered or administrative controls. b. Examples of fall prevention systems include, but are not limited to, the following: 1. Guardrails with midrails and toe boards; 2. Ladder cages; 3. Warning line systems six feet from the edge; 4. Controlled access zones; 5. Covers for holes in floors, roofs, and other walking/working surfaces; and, 6. Spotters and monitors. D. Fall Protection a. If a fall prevention system cannot be used, fall hazards can be controlled by implementing fall protection systems. b. Workers must be protected from fall hazards where the worker could fall 4 feet or more or falling less than 4 feet onto dangerous equipment. 36 c. Where the worker will be within 6 feet or less from a fall hazard (typically a horizontal distance), identify the appropriate means of protection (i.e., netting, scaffolding, 100% tie-off, or other fall arrest means). d. 100% tie-off is required when working in man lifts or powered platforms using a harness and lanyard with a deceleration device. e. Fall protection is not required when personnel are working on permanent ramps, runways, work platforms, other walkways, or tank landings equipped with top rails, midrails, and toe boards. f. Tether tools or secure them with other means to prevent objects from falling. E. Equipment Selection a. Select components for PFAS/PFRS in accordance with current ANSI requirements. b. Only appropriate full body harnesses will be used. c. Only appropriate lanyard(s) and connecting hardware will be used. F. Equipment Implementation a. Equipment selected will be appropriate for the operation. b. Equipment will be inspected before each use for any defects that could affect the system’s safe operation and function. c. Equipment will be inspected annually by a competent person for safe working condition. If equipment does not meet the requirement, it will be destroyed or recertified by a qualified source. d. Fixed anchor points must be adequate and verified to meet requirements including documented inspection. e. Ladder climbing devices must be adequate and verified to meet requirements including documented inspection. f. Defective ladders will not be used. G. Rescue Plans – Prompt rescue in the event of a fall must be planned for before initiation of working at heights. Verification that a worker is able to perform self-rescue is also allowed. VI. Training A. Training will be provided to employees on hazard recognition, care and safe use of equipment, storage and maintenance, and limitations of fall protection systems. B. Each user must demonstrate an understanding of the proper use of the devices. C. Retraining will be conducted when site, job duties, or systems change, which presents new fall hazards; when the type of equipment to be used has changed; previous training becomes obsolete; or when it appears an employee does not have the required understanding or skill regarding fall hazards or protective measures. 37 VII. Revision History The table below lists all changes made to this section since the implementation of the program: 38 Section 11 ERGONOMICS I. Purpose The purpose of this section is to ensure ergonomic risk factors are managed to prevent work- related injuries or illnesses. The program will provide a framework for the activities that are necessary to identify, manage, control and eliminate ergonomic hazards in the workplace. II. Scope This program applies to all employees while performing work tasks and is intended to address activities that require significant forces, awkward and static postures, repetitive motion, vibration and other work-related risk factors. III. Definitions A. Administrative controls – changes in the way that work in a job is assigned or scheduled that reduces the magnitude, frequency or duration of exposure to ergonomic risk factors. B. Ergonomics - the science of fitting jobs to people encompassing the body of knowledge about physical abilities and limitations as well as other human characteristics that are relevant to job design. C. Engineering Controls – physical changes to a job that eliminate or reduce the presence of ergonomic hazards. Examples of engineering controls may include changing, modifying, or redesigning work stations, tools, facilities, equipment, materials or processes. D. Ergonomic Risk Factors – aspects of a job that post a biomechanical stress to the employee, such as forceful exertion, repetition, awkward or static postures, contact stress and vibration. E. Ergonomic Injuries and Illnesses – injuries and illnesses of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal discs. It does not included injuries caused by slips, trips, falls or other similar accidents. Examples of ergonomic injuries and illnesses include: carpal tunnel syndrome, De Quervain’s disease, Sciatica, Epicondylitis, Tendonitis and herniated spinal disc. F. Signs and Symptoms – objective physical findings or physical indications that an employee may be developing an ergonomic injury or illness. IV. Responsibilities A. The manager will ensure the following activities are completed. a. Ensure all employees are provided the opportunity to participate in the program. 39 b. Identify any ergonomic risk factors. c. Develop and implement feasible controls to reduce ergonomic hazards. d. Ensure implementation of a medical management program for diagnosis and treatment of injuries and illnesses if necessary. e. Ensure training is provided on this program. f. Maintain worksite surveillance of the effectiveness of the program and develop action items as necessary. B. Employee Responsibilities. a. Notify management of signs and symptoms of ergonomic injuries and illnesses and work-related ergonomic risk factors. b. Participate in all aspects of the program, such as submitting concerns related to risk factors, discussing work methods, offering suggestions in problem solving exercises, and participating in all related education and training. C. Safety Department Responsibilities. a. Oversee and coordinate the medical management of ergonomic injury/illness cases. b. Coordinate any work restrictions. c. Assist in evaluation and improvement of the work environment. V. Procedure A. Reporting Procedures a. Reported signs or symptoms of ergonomic injuries/illnesses must be recorded, managed, and investigated for potential immediate fixes. Ergonomic injuries or illnesses that meet the criteria for recordability must be also recorded on the OSHA 300 log. b. If the condition cannot be immediately addressed and a long-term corrective action is needed, the affected employee will be kept apprised regarding the status of the reported issue(s). B. Worksite Analysis a. An analysis will be conducted on an as-need basis and should include risk factors associated with force, repetition, awkward and static postures, contact stress, vibration, and other work-related risk factors. b. Management will monitor the workplace to detect new or additional risk factors and ensure the adequacy of the completed analyses. C. Hazard Prevention and Control – the standard hierarchy of controls followed should be: a. Elimination; b. Engineering Controls; c. Work practice or administrative Controls; d. Personal Protective Equipment; e. Controls should be identified and implemented for work-related ergonomic hazards. Lifts should be monitored and machinery used whenever possible. 40 D. Medical Management a. Employees must report work-related ergonomic injuries and illnesses promptly. b. Access to health care professionals will be in accordance with existing Worker’s Compensation policies. c. Information will be provided to the health care professional about the job tasks and/or existing Worker’s Compensation policies when directed. d. Management will provide restricted employees work that is consistent with the employee’s capabilities per existing policies. E. Education and Training – training will be provided as needed and will include: a. Ergonomic risk factors relative to the work. b. Controls used to minimize or eliminate ergonomic hazards. c. Signs and symptoms of ergonomic related injuries and illnesses. d. Reporting and recording procedures. e. The employee’s role in evaluating the effectiveness of the ergonomic program. VI. Revision History The table below lists all changes made to this section since the implementation of the program: 41 Section 12 ELECTRICAL SAFETY I. Purpose The purpose of this section is to protect employees, contractors, and sub-contractors from injury associated with electrical hazards in the workplace. Compliance with this section will ensure that the company achieves a consistent standard of care as it relates to electrical safety. II. Scope The program applies to all employees who work on or near electrical hazards in the workplace. All workers must comply with OSHA, NFPA 70E, and other regulatory standards. III. Definitions A. Electrical Hazard. A dangerous condition such that contact or equipment failure can result in electric shock, flash burn, thermal burn, or blast. B. Flash Hazard Analysis. A study investigating a worker’s potential exposure to arc flash energy, conducted for injury prevention and the determination of safe work practices and the appropriate levels of PPE. C. Flash Protection Boundary. An approach limit at a distance from exposed live parts within which an employee could receive a second-degree burn if an electrical arc flash were to occur. D. PPE. Personal Protective Equipment. E. Qualified Employee. An employee trained on and knowledgeable of the electrical equipment to be evaluated, safe methods of using test equipment, and in the recognition of electrical hazards that might be present with respect to that equipment and the voltage involved. These are the only employees allowed to enter a flash protection boundary after approved by a manager. IV. Responsibilities A. Managers: a. Implementation of and adherence to the program. b. Providing and make available appropriate PPE to employees. c. Providing appropriate and approved electrical testing equipment. d. Ensure that PPE and electrical testing equipment are properly tested and in good condition. e. Ensure employees are trained on electrical hazards, the safe use of field testing equipment and the use, care and cleaning of PPE. B. Safety Department: a. Maintain records of training and electrical field testing equipment and PPE supplied. b. Ensure defective or damaged equipment is immediately removed from service. c. Conduct walk-thru inspections to ensure labeling and other regulatory requirements are met. d. Ensure appropriate assistance is provided to employees where questions or concerns arise regarding inspection situations. 42 C. Employees: a. Attend electrical safe work practices training. b. Know how to determine the nature and extent of the potential electrical hazard. c. Be familiar with appropriate PPE and safe approach distances. d. Be familiar with the use and hazard of appropriate electrical test equipment. V. Procedures A. General 1. Safety-related work practices will be used to safeguard employees from injury while working on or near exposed electrical conductors or circuit parts that are on or can become energized. The specific safety-related work practice shall be consistent with the nature and extent of associated electrical hazards. 2. The nature and extent of the electrical hazard shall be determined, including any flash hazard, prior to proceeding with any work. 3. Only qualified, approved, and properly equipped employees or contractors will be permitted within the flash protection boundary of energized electrical equipment. 4. Unqualified employees will not be permitted to enter the flash protection boundary unless the electrical conductors and equipment involved are in an electrically safe work condition (i.e. LOTO, de-energized, etc.). B. Specific 1. Laramie will select approved and qualified electrical contractors to perform most tasks including construction, maintenance and troubleshooting. The contracting company will be responsible for providing workers, PPE and equipment appropriate to the job and that meet all industry standards. 2. Live parts to which an employee or contractor may be exposed shall be de-energized before work can begin on or near them, unless it can be demonstrated that de-energizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations. If it is necessary to work live (greater than 50V to ground), an arc flash hazard calculation shall be conducted. 3. Protective measures will be implemented. Examples of this include, but is not limited to: selection of proper PPE, guarding of all live parts 50V or greater, ground and bonding of electrical equipment, distance requirements from live overhead lines, precautions to ensure electrical equipment/systems are de-energized and the use of electric tools for the intended design/rating. 4. A Job Safety Analysis will be conducted for any non-routine work that may expose workers to the hazards of electrical energy and include the required measures to mitigate the identified hazards. VI. Training 43 A. Qualified workers. Qualified Workers will receive the necessary training on and be knowledgeable of: a. Electrical tasks they are qualified to perform; b. Electrical hazard assessment results and permits if required; c. Determination of PPE selection for tasks being performed; d. Safe work practices to be used for each task; e. Determination of minimum approach distances from energized equipment; f. Determination of safe stand-off distances from energized overhead power lines; g. Assess intended use of electrical testing equipment and verify proper testing range. B. Unqualified workers. Unqualified Workers will receive the necessary training on and understand: a. How to identify electrical hazards in the workplace; b. Electrical warning sign identification and meaning in the workplace; c. Limitations of their training and allowances. C. Qualified and Unqualified workers will receive additional training on this program when there is reason to believe that electrical safety-related work practices were not followed. VII. Recordkeeping A. Written records will include the source of the training, the employees trained, a description of the training provided, and the dates that the training occurred. B. All training records will be maintained in the safety department. VIII. Revision History The table below lists all changes made to this section since the implementation of the program: 44 Section 13 HYDROGEN SULFIDE I. Purpose The purpose of the Hydrogen Sulfide program is to provide guidance to Laramie Energy employees and contractors for safe work around facilities with varying levels of hydrogen sulfide (H2S) and to ensure that information about the dangers of this toxic gas are known by all affected personnel, and to ensure that proper controls are in place to mitigate the hazards associated with H2S. II. Scope H2S is a flammable, acidic, and toxic gas that is present at many petroleum exploration and production sites as a component of crude oil, natural gas, produced water, and condensate. This program provides an awareness of the protective measures that are required when working around H2S as well as the physical properties, symptoms of exposure, and associated hazards. Laramie expects all personnel accessing a site where the potential for H2S exposure exists to be aware of the properties and hazards associated with H2S gas. III. Definitions Ceiling - A ceiling is an exposure limit that is not to be exceeded at any time during a workday. Exposure is typically monitored using a direct-reading devise with an alarm to give an instant indication. Exposure limit - An exposure limit is the maximum permitted employee and contractor exposure level in company workplaces for the time period listed. Four types of exposure limits exist based on potential exposure time. They are as follows: Exposure type Exposure time Exposure Limit (ppmv) Ceiling Instant 15 TWA 8 8 hours 10 TW10 10 hours 7 TW12 12 hours 5 45 Time-Weighted Average - Airborne concentration of a substance as an average over a specified time period, which is generally given after the acronym (e.g., in TWA8, the specified time is 8 hours). Immediately Dangerous Any atmosphere where the concentration of oxygen, flammable, To Life or Health (IDLH) - or toxic air contaminants would cause a person without respirator protection to be fatally injured or cause irreversible and incapacitating effects to that person’s health. IV. Responsibilities A. Safety department is responsible for developing, communicating, evaluating, maintaining, and improving this program. They will also be responsible for making the program available to employees and contractors when needed and providing appropriate training materials and system tools. B. Managers are responsible for implementing this practice, making aware when changes or updates to the program are needed and, ensuring that all personnel under their authority, inclusive of contractor personnel, are adequately trained and knowledgeable in the fundamentals of the H2S program to a level reflective of their individual responsibility within the program. C. Employees and contractors are responsible for following the H2S program and incorporating its requirements into all associated work. V. Procedures A. Associated Hazards a. Iron sulfide (FeS) – A pyrophoric material that is the byproduct of H2S reacting with carbon steel, such as in a pipeline or equipment. Typically, this material is a gray powder, but may be attached to rust particles making it difficult to distinguish from rust or other gas pipeline material. It will self-ignite when dried and exposed to air. Control measures include continually wetting it or covering it with another material, such as soil or lime, so as to separate it from the air. b. Sulfur dioxide (SO2) – A gas that results from the combustion of H2S. This material is almost always present at the tip of an active flare particularly in sour gas areas. It distributes readily in air such that if it is released from an elevated area, it will rarely sink to ground level. SO2 gas reacts with mucus membranes of the eyes and nose to form sulfuric acid. The resulting irritation rarely enables an individual to remain exposed to the gas for a significant period of time. The ACGIH short-term exposure limit (STEL) for SO2 is 0.25 ppm. The OSHA permissible exposure limit (PEL) is 5 ppm. 46 c. Carbon disulfide (CS2) – A yellow, sweet (or potentially very foul) smelling liquid sometimes found with condensate or other pipeline liquids. Typical routes of exposures are vapor inhalation and skin absorption. Overexposure may cause various neural effects – the material is also a reproductive toxin. The PEL of CS2 is 20 ppm. d. Internal pipeline or equipment corrosion – Condensed liquids (water) combined with H2S – contaminated gas in the presence of very little oxygen or carbon dioxide will result in severe corrosion to carbon steel over time and can lead to a containment failure. This corrosion type is characterized by pitting. e. Sulfide stress cracking (SSC) – The failure of steel caused by the simultaneous action of stress and hydrogen absorbed from corrosion by H2S in water. This failure will typically occur near welds or other potential areas of metal stress and will lead to a breach of containment. B. Identifying and testing H2S sources Identify and document all areas where greater than 10 ppm sources of H2S gas exists. Such areas must be listed by the maximum level of H2S in stream or vapor space, whichever is greater. Production facilities must be monitored following the addition of new well flow. H2S concentrations shall be determined for both liquid hydrocarbon oil and produced water tanks. H2S can be generated by biological activity. The potential is present in areas containing frac or flowback water (tanks, pits) or at water treatment facilities. These areas must be tested and documented as well. Risks of H2S generation by biological agents can be controlled by actively monitoring flowback water quality and by using biocides as the need indicates. Measure H2S using direct reading instruments, colorimetric tubes, or stream analysis. Retest areas with H2S concentrations greater than 50 ppm at least annually. Conduct the tests when the maximum H2S concentration would be expected, such as during the warmer months of the year. Follow confined space entry procedures when testing cellars, bellholes, or any other confined spaces. Areas where concentrations of H2S are known or suspected to exceed 10 ppm in the breathing zone or 100 ppm in the vapor space will need to comply with respiratory protection requirements. C. Warning signs and access control Included below are the minimum standards for H2S signage and access control. State and local jurisdictions may have different or more stringent requirements and should be referenced in conjunction with this program. 47 To warn both employees and the public of H2S hazard, install or provide signs or labels to be readable at a distance of 50 feet. The signs should read Caution Poison Gas at: • The normal access point to a facility in which process or production equipment contain greater than 100 ppm H2S. • On roads which provide direct access to any facility handling H2S gas with 100 ppm or greater concentration. In addition, • Signs reading Respiratory Protection Required Beyond this Point shall be included in areas where greater than 10 ppm measured in the breathing zone has been demonstrated to exist under normal maintenance or operations (such as tank gauging) and Wind socks or other suitable wind direction indicators will be provided at the following locations: • Plant sites where the 100 ppm radius of exposure is 50 feet or greater; • Tank batteries where concentrations of H2S exceeding 100 ppm are present in the vapor space of stock tanks; and, • Compressor facilities where concentrations of H2S exceeds 100 ppm in the gas stream. D. Respiratory protection All personnel assigned to work in operations where the workplace breathing zone concentrations of H2S have been demonstrated to exceed the occupational exposure limit (OEL) of 10 ppm shall have access to respiratory protection. Personnel shall be trained in the selection, use, inspection, and maintenance of equipment; must undergo a medical evaluation; and be fit tested. At a minimum, PPE will be: • Self-contained, positive pressure breathing equipment (SCBA) • Positive pressure, air-line breathing equipment with an auxiliary self-contained air supply (minimum 5 minute rated) for emergency egress use only. The use of respiratory equipment is mandatory in areas measuring 10 ppm H2S or greater in the breathing zone or when gauging or opening equipment containing 100 ppm H2S measured in the vapor space. Where H2S is likely to be present in compressors or piping, test the area before beginning work. This is particularly important when working below grade in pits, vaults, or excavations due to their heavier nature of H2S relative to other gases and the tendency of it to settle in low lying areas. When possible, residual gas containing H2S should be allowed to dissipate over time. 48 Emergency respiratory protection must be provided at manned locations where H2S in concentrations greater than 100 ppm is known to exist in the gas stream. Such protection may be provided in other situations and circumstances as determined by risk or the authority having jurisdiction (i.e. BLM). Emergency respirators must undergo a documented monthly inspection. Personnel who may be required to don respiratory protection in an emergency situation cannot have facial hair that interferes with the seal of the respirator mask. Well drilling operations occurring in or near a zone known to contain H2S may be subject to additional requirements. E. Monitoring and detection Personal monitoring refers to portable quantitative equipment that is worn within the breathing zone (i.e. within one foot of the face). Personal monitors are designed to provide fast and reliable warnings against hazardous concentrations of H2S. Such monitors must have an audible and vibrating alarms set at 10 ppm and a concentration readout on the unit. Personal H2S monitors shall be used in the following situations: • In areas of limited dilution ventilation where no fixed detection is provided and the concentration of H2S could exceed 10 ppm in the breathing zone. • During activities which may release H2S into the atmosphere in the immediate work area. If an alarm activates on a personal H2S monitor, workers shall evacuate in a direction that is perpendicular to that of the wind. When possible, work in known or suspected H2S areas should occur downwind of personnel. Fixed monitoring refers to quantitative detection or monitoring equipment that continuously measures the concentration of H2S in ambient air. The sensors are normally connected to a central controller and alarm system that is activated upon detection of an H2S concentration. Fixed monitoring may be installed under these conditions: • In the work area of a manned facility where there is a possibility for the accumulation of H2S in concentrations greater than 10 ppm. • In manned areas where the material contained in piping and equipment is of sufficient H2S concentration (gas treaters and other H2S processing equipment) that would result in large areas of potential employee exposures exceeding 10 ppm if a release occurred. • At a minimum, at all unmanned facilities where the 100 ppm radius of exposure is greater than 3,000 feet or includes a dwelling, public place, or public road (state and local regulations may have additional requirements) 49 If a high alarm activates, personnel shall immediately move upwind and crosswind from the area. If re-entry to the area is deemed necessary to investigate and correct the cause, personnel shall don respiratory protective equipment and monitor their personal H2S detector during re-entry. The worker shall not re-enter the area if the concentration exceeds 100 ppm until a second worker arrives. The stand-by worker, equipped with an SCBA, shall maintain audible or visual contact with the first worker and be prepared to perform rescue if required. When an alarm activates at an unmanned facility, personnel responsible for the facility shall be notified of the alarm condition. It shall be his or her responsibility to assess the situation and either control the source of the release or activate the Emergency Response Plan for the facility. F. Risk assessment and controls For sites where the potential for H2S to occur in production, storage, transportation, or processing, the risk of release shall be evaluated and controlled as determined through a risk assessment process. Risks may be addressed by using any of the following methods individually or in combination: Engineering Controls – automatic shutoff valves or equipment shutdowns actuated by fixed H2S monitors, fencing and site entry controls where H2S concentrations exceed 100 ppm, and automatic tank gauges Administrative Controls – signage and windsocks, training of appropriate personnel, Emergency Response Plans or H2S Contingency Plans, standard operating procedures Personal Protective Equipment – Personal H2S monitors with alarms, Supplied air respirators or SCBA. G. Well Drilling and Completions Where drilling and completions operations are in effect or planned to be, precautions must be taken to ensure operations are safe when working around H2S or the potential for H2S. Personnel must adhere to regulations including, but not limited to: a. COGCC Rule 607 b. BLM Onshore Order 6 c. API RP 49 (API conditions I, II, and III) H. Emergency Response In the event of an H2S release or high alarm, personnel must evacuate upwind and crosswind if possible and comply with existing escape routes if designated. Personnel should use appropriate escape equipment if available. VI. Training 50 A. Training shall occur upon initial assignment, when conditions change to the level that additional or refresher training is deemed necessary, or when a worker demonstrates that their lack of knowledge or understanding would indicate refresher training is needed. B. The H2S training agenda and content shall adhere to the requirements set forth in ANSI Z390.1: a. Hazards, characteristics and properties of H2S. b. Sources of H2S. c. Proper use of H2S detection methods used. d. Recognition of and proper response to warning signals for H2S release. e. Symptoms of H2S exposure. f. Emergency rescue response safety precautions. g. Wind direction awareness and routes of egress. h. Operation of respiratory equipment and practice in its use, including restrictions regarding facial hair. i. Basic first aid and CPR procedures as they relate to H2S exposures. j. Corrosion effects on metals. k. Contingency planning. C. Managers and supervisors responsible for operations with potential H2S exposure will have current H2S training. D. Contractors working in areas where H2S is present at greater than 10 ppm shall provide current documentation of their employee H2S training and respirator fit testing and be advised of location safety and emergency procedures. E. If it can be avoided, visitors must stay away from H2S locations. But, if it cannot be avoided, at sites that have concentrations of 100 ppm or greater, they shall be accompanied by a trained employee with an H2S monitor and be briefed on: a. Site specific sources of H2S b. Routes of egress and muster points in case of alarm c. Alarm signals and meaning d. Hazards and health effects of H2S VII. Recordkeeping A. Site H2S measurement results will be kept by the company and distributed as necessary. B. Employee respiratory protection training and fit testing documentation shall be maintained by the company. Medical evaluations will be kept in compliance with local, state and federal standards. 51 VIII. Revision History The table below lists all changes made to this section since the implementation of the program: 52 Section 14 EXCAVATION/GROUND DISTURBANCE EXCAVATION/GROUND DISTURBANCE I. Purpose II. Scope III. Definitions IV. Responsibilities V. Procedures a. Requirements b. Inspections c. Access and Egress d. Air monitoring e. Falling objects f. Protective systems g. Entry VI. Training VII. Recordkeeping VIII. Revision History IX. Supporting Documents (authorization form) Excavations Prior to beginning any excavation activity, the Employee shall locate subsurface pipelines or other buried utilities that may cross any proposed excavation or subsurface investigative activity using the state "One-Call" system(s). The Employee shall determine the exact location of buried facilities by hand digging the final 18" or by other safe method when excavation approaches the estimated location of a buried structure. The Employee shall ensure that exposed underground facilities are properly supported and protected. The PM shall ensure that a person the company deems competent to oversee, to monitor, and to inspect an excavation site, is on-site whenever work is occurring in an excavation. This person shall be trained and certified as specified by the OSHA standard per 29 CFR 1926 Subpart P. OSHA sloping or shoring rules shall be strictly followed as specified in 29 CFR 1926 Subpart P. Such competent person shall inspect excavations, the adjacent areas and protective shoring systems (or benching) for evidence of possible cave-ins, failures, hazardous atmospheres or other hazardous conditions. Employees exposed to a hazardous condition shall be removed from the area until necessary precautions have been taken. The Competent Person must conduct inspections: • Each day, prior to the start of work; • As needed throughout the shift; and • After a change in weather conditions (i.e., rainstorm, snow, etc.) or other event that could pose a hazard. 53 The Employee shall obtain ladders or sloped walkways for safe entrance and exit for personnel working in trenches or excavations four (4) feet or more in depth. The Employee shall provide emergency exits within 25 feet laterally from any point where personnel are working in a trench. No person will be permitted to work in excavations while excavation or other heavy equipment is being operated nearby. All materials and equipment must be kept at least two (2) feet from the excavation to protect Employees from the hazard of material and/or equipment falling or rolling into the excavation. 54 Section 15 HOT WORK I. Purpose This section provides a summary of Laramie Energy’s Hot Work Permit program. It applies to employees and contractors at all facilities owned and operated by Laramie Energy. All hot work will be conducted in accordance with this Hot Work program. II. Scope The purpose of this section is to ensure employees and contractors safely manage hazards involved with hot work. This section complies with all regulatory requirements including 29CFR 1910.252(a). This will: • Cover welding, cutting, brazing, burning, grinding or other forms of hot work that can produce a spark or flame in an area or on equipment, which contains or has the potential to contain flammable or hazardous materials; • Create and maintain a safe work environment for any work that may create an ignition source in a potentially hazardous work environment; • Set minimum standards for hot work that must be supplemented with separate procedures at the site as required by local conditions or special situations; • Prevent the accidental ignition of explosive, flammable, or combustible materials by ensuring that flammable or combustible materials are absent, isolated, protected, or removed from the work areas within which any type of hot work will be conducted; • Prevent unnecessary exposure of personnel to the potential hazards associated with hot work, thereby mitigating the risk of potential injury or damage to the assets; and • Define an Authorized Permit Writer, describe their role and responsibilities, and recognize requirement of an authorized contractor performing the work to also sign the permit. This program requires that all Hot Work Permits be signed by an authorized Laramie Energy representative and an authorized contractor representative. III. Definitions Hazardous location A location or area where fire or explosion hazards may exist due to the presence of flammable gases or vapors, flammable liquids, combustible dust, or ignitable fibers or flyings. Hot Work A work activity or operation that can produce enough heat from flame, sparks, or other sources of ignition with sufficient energy to cause the ignition of fires or explosions from flammable vapors, gases, liquids, or dust. This will include but is not limited to: 55 • Welding, cutting, grinding, brazing, burning, soldering, heating, drilling, riveting, air gouging, chipping and all open flames; • Use of any AC or DC powered tool or electrical equipment that is not intrinsically safe; and • Introducing internal combustion engines/sources within a potentially hazardous area. Hot Work Permit Area Areas that are near any potential hydrocarbon or flammable vapor or liquid source (e.g. wellheads, process vessels, storage tanks or bullets, vents, PSVs and drains) and combustible materials. Authorized Permit Writer An employee or person working under contract to Laramie Energy who: • Has been designated by management and is trained and competent to perform the hot work writing and • Is directed by Laramie Energy to oversee contractors on Laramie Energy locations. IV. Responsibilities Managers Responsible for implementation of program, providing adequate resources to support this program, and approving, in writing, any hot work to be conducted in areas where the measured LEL cannot be mitigated to less than 10%. Safety Staff Responsible for implementing program, providing training and resources for program, and reviewing permits upon completion. Authorized Permit Writer Responsibilities include: • Ensure that atmospheric testing is conducted as required on the Hot Work Permit (continuous or intermittent). • Inspect the job site and ensure that compliance requirements on Hot Work Permit are met. • Provide appropriate isolation methods as indicated on the permit (lock out/tag out, etc.). • Ensure barriers cover or seal all openings in floors (e.g. drains and sewers), walls or ducts within 35 feet of work as required. • Ensure fireproof welding blanket, curtain, pads, water fog or other protection necessary to contain ignition sources from combustible or 56 flammable materials and nearby equipment is available and utilized as required. • Ensure proper ventilation, as required. • Ensure fire watch personnel are trained and properly equipped. • Conduct a JSA with all involved personnel including Laramie Energy employees and contractors working in the area or that may be affected by the hot work. • Inspect the work site and adjacent area 30 minutes after the work is completed (one hour in Colorado). • Ensure a copy of the Hot Work Permit is turned into Safety Department for review and filing. Ensure the hot work has been completed and the area is returned to routine operations. • Review the Hot Work Permit with operations personnel, pumper, lead or manager. • Stop any operations that may conflict with the permitted work. Instruct all personnel to stop work if a change occurs that may create a hazardous or unsafe condition. • Verify within 35 feet of work: floors have been swept clean, combustible floors kept wet, combustible materials relocated or protected, combustible or explosive atmospheres have been eliminated. • Make sure the Hot Work Permit has been filled out completely. • Obtain proper signatures on permit including those performing the work and the fire watch, as required. • Issue the Hot Work Permit only after all site preparation has been completed, relevant personnel have been notified and the permit is signed by both Laramie representative and contractor representative. • Conduct follow-up testing as required and after any interruptions or breaks of more than one hour. • Remain at the work site until the first arc, spark or ignition source is created. • Ability to transfer authority to another Authorized Permit Writer. Fire Watch The fire watch shall be required during welding, cutting, brazing, grinding and other flame-producing activities. Fire watch personnel must be properly trained on the Hot Work program and on the use of fire extinguishing equipment. Fire watch responsibilities include: • Have the fire extinguishing equipment readily available (minimum 20-lb of Type ABC). This does not include site fire protection equipment. • Attempt to extinguish fires within the obvious capacity of the equipment; otherwise, sound the alarm. 57 • Assess conditions during the hot work and for at least 30 minutes after completion of the work (one hour in Colorado). • Stop work if sparks, flame, slag or heat moves beyond the permitted area. • Alert any personnel entering the permitted area of existing hazards. • Be properly trained in Emergency Response Plans and Procedures. V. Procedures a. Preliminary Requirements. Every hot work job has unique hazards. All precautions must be made to provide a safe work environment prior to commencing work. Before beginning any hot work, the following situations and requirements must be considered: • A Job Safety Analysis (JSA) is required to be completed before issuing a Hot Work Permit and communicating the job scope to all affected personnel. The contractor performing the hot work may use their JSA to communicate these hazards. • Local government restrictions may supersede this practice (e.g. fire restrictions or burn bans). • Special precautions must be taken to avoid accidental operation of automatic fire detection/suppression systems and fire eyes. • Fire prevention and protection for the Hot Work Permit requires that a minimum of at least one 20-lb dry chemical fire extinguisher shall be available in the immediate area during welding or cutting operations. This fire extinguisher is in addition to the general fire protection equipment on site. In addition, one should consider first protecting combustibles from ignition before commencing hot work or requiring a Hot Work Permit by: • Considering alternative methods to the hot work (where practical); • Moving the work to a location that is free from combustibles; • If the work cannot be moved, moving the combustibles to a safe distance or having the combustibles properly shielded or protected against ignition; or • Scheduling hot work so that operations that could expose combustibles to ignition are not started. b. Conditions Restricting Work. Hot work will not be permitted in the following situations: • In confined spaces without following the requirements of the Confined Space Program; • In the presence of an explosive atmosphere; • In areas near storage of large quantities of exposed, readily ignitable materials; • Where ignition can be caused by heat conduction; or • On used containers, such as drums and tanks, unless properly cleaned. 58 • When work is not started within one hour or the hot work is delayed or suspended for more than one hour, a retest of the LEL and oxygen is required. The permit may be voided and a new one issued in this case at the Authorized Permit Writer’s discretion. c. Requirements. The three primary types of hot work may or may not require a Hot Work Permit as discussed in the following sections. 1. Cutting, welding, grinding, brazing, and open flames. These are the most critical hot work activities that have a potential for creating a fire or explosion. A Hot Work Permit and a Fire Watch shall be required when: • Combustible or flammable materials are closer than 35 feet or further if conditions warrant; • Combustible or flammable materials are more than 35 feet away but are easily ignited by sparks; • Wall or floor openings within 35 feet of exposed combustible material in adjacent areas (e.g. concealed spaces in walls or floors). • Combustible or flammable materials are adjacent to the opposite side of partitions, walls, ceilings, or roofs and are likely to be ignited; and • When welding or cutting is performed on locations where a fire might develop. 2. Non-intrinsically safe/electrical equipment. Fixed or portable (non-intrinsically safe) non-classified electrical equipment should be used at a safe distance. Where flammable gas vapor may be present, atmospheric testing is required. In this case, atmospheric testing may be done without the use of a Hot Work Permit if a risk assessment has been completed and standard operating procedures are used. A fire watch is not required in these situations. 3. Combustion engines and external sources. Combustion engines that are temporarily positioned in areas where flammable gas vapor may be present require atmospheric testing and may require a Hot Work Permit. Individuals must document atmospheric testing results. Internal combustion engines including vehicles that operate within 10 feet of a classified area shall require notification to Laramie employee or designee, but not a permit: transit, snow removal, routine well servicing, delivery of parts and materials, and manned well servicing operations such as coiled tubing units, slickline units, boom cranes, etc. Other vehicle usage situations may require a risk assessment or other means to ensure safe usage of the vehicle within a classified area or hot work permit area. External combustion sources, such as temporary heaters and flares, also may introduce hazards related to contact with open flames. For external combustion sources where a flammable gas vapor may be present, atmospheric testing is required and a Hot Work 59 Permit may be required. The atmospheric testing results must be documented. A fire watch is not required in this situation. d. Permitting. A JSA must be completed and a Hot Work Permit shall be obtained before starting any work that may involve a source of ignition and is within 50 feet of a potential hydrocarbon or flammable vapor, liquid source, or combustible materials. The permit shall be in writing and should include the following: • The fire prevention/protection requirements and special precautions that must be implemented before commencing the hot work; • The type of work (welding, grinding, electric tools, etc.), the object on which the hot work is to be performed, and the date and permit expiration; • The person initiating the Hot Work Permit, who must be designated and trained and must be an Authorized Permit Writer. • Atmospheric testing for lower explosive limit (LEL) and oxygen monitoring including if monitoring was intermittent or continuous; • Fire Watch requirements; • Personal Protective Equipment requirements; • Isolation requirements and methods where applicable (e.g. purging, blinding, double block & bleed, energy isolation, flushing, and ventilation); and • Signatures by both the Laramie Energy representative and the contracting company’s representative. The following are also required for hot work permitting: • The Hot Work Permit is to be issued at the physical job site where the work is to be performed. • Hot Work Permits are approved for only one shift (12 hours maximum). A new permit must be issued for a new shift. • All affected personnel shall be notified of the Hot Work. • A change in conditions making continuation of the hot work hazardous voids the permit (STOP WORK) and a new permit must be issued. • A change in the make-up of the crew performing the hot work (welder, fire watch, helpers, etc. who are directly involved in the hot work) requires that the new member of the hot work team be properly oriented on the aspects of the hot work process. A JSA must be reviewed/completed by this person before commencing the hot work. The new member will also sign the hot work permit. e. Atmospheric testing during hot work. Atmospheric testing shall be conducted for any Hot Work. Monitoring for toxic substances should be based on the information from the JSA. In addition, the following must be completed for atmospheric testing: 60 • Atmospheric gas testing shall be conducted in the presence of the work group. • Continuous and intermittent atmospheric monitoring for LEL and oxygen may be required as deemed necessary by the Authorized Permit Writer and will be indicated on the Hot Work Permit. • If the LEL consistently reads 10 percent or higher, hot work must stop and the source of flammable atmosphere identified and eliminated or controlled before work resumes. If the LEL cannot be mitigated below 10 percent, an attachment to the Hot Work Permit will be written that details procedures for controlling the ignition source. The procedures shall be approved in writing by the manager responsible for the work. • Oxygen tests results must be between 19.5 and 23.5 percent. • It is the permit issuer’s responsibility to ensure the gas detection equipment being used is appropriate and calibrated before use. • Fixed gas detection shall not be used for the gas checks or continuous monitoring. VI. Training Awareness level, Fire Watch and Authorized Permit Writer training will be conducted as applicable for all personnel whose work assignments may involve hot work and may include the following topics: • Fire extinguisher operation, • Hot work program and permit, • Fire protection, • Atmospheric gas monitor operation, maintenance and calibration, • Emergency Response Plans and Procedures, • Job Safety Analysis, • Lockout/Tagout and hazardous energy isolation, • Hazardous communication (SDS), • Hydrogen Sulfide awareness, and • Confined space (applicable to the job). Refresher training will be provided whenever ignition or flammable hazards in the workplace change significantly or an evaluation of the program reveals inadequacies in the worker’s knowledge of the program. VII. Recordkeeping The Hot Work Permit must be kept on location for the duration of the hot work activity. Completed Hot Work Permits will be kept on file with the safety department. A sample of these permits will be kept for 12 consecutive months for program review. VIII. Revision History 61 The table below lists all changes made to this section since the implementation of the program: IX. Appendix a. Hot Work Permit b. Hot Work Permit guide 62 Section 16 FORKLIFT/INDUSTRIAL TRUCKS FORKLIFT/INDUSTRIAL TRUCKS I. Purpose II. Scope III. Definitions IV. Responsibilities V. Procedures VI. Training VII. Recordkeeping VIII. Revision History IX. Appendices (pre-trip checklist) Industrial Trucks and Heavy Equipment The most common type of heavy equipment used by Laramie Energy is for road or well pad construction and maintenance activities or for over the road hauling. While earth-moving and over-the-road trucks are excluded from the provisions of 29 CFR 1910.178, all types of heavy equipment that are covered by these regulations must comply. In general, Laramie Energy requires that all personnel and contractors who operate equipment must be properly trained and have the required certification/license to operate heavy equipment including: industrial trucks, skid loaders, bulldozers, back hoes, forklifts, dump trucks, front-end loaders, motor graders, or cranes. All heavy equipment must have a warning horn, whistle, gong, or other device which can be clearly heard above the normal noise in the area where operated. Before using these vehicles, check that the brakes on each industrial truck are capable of bringing the vehicle to a complete and safe stop when fully loaded. The parking brake must effectively prevent the vehicle from moving when unattended. 63 Section 17 POWER AND HAND TOOLS POWER AND HAND TOOLS I. Purpose II. Scope III. Definitions IV. Responsibilities V. Procedures a. OSHA and NEC compliance b. Maintenance c. Safety shut offs d. Guards e. Cords/GFCI VI. Training VII. Revision History Tool Maintenance Faulty or improperly used hand tools are a safety hazard. All workers shall be responsible for ensuring that tools and equipment (both company and operator-owned) used by them or other workers at their workplace are in good condition and properly maintained as required by 29 CFR 1910.242. Hand tools must be reconditioned or replaced as necessary. Broken or fractured handles on hammers, shovels, axes and similar equipment must be replaced promptly. Appropriate handles must be used on files and similar tools. Appropriate safety glasses, face shields, etc., must be worn while using hand tools or equipment which might produce flying materials or be subject to breakage. Check your tools often for wear or defects. Jacks must be checked periodically to assure they are in good operating condition. Tool handles must be wedged tightly into the heads of tools. Tool cutting edges should be kept sharp enough so the tool will move smoothly without binding or skipping. When not in use, tools should be stored in a dry, secure location. Machine and Power Tools Personnel operating power equipment must be trained on safe methods of machine or power tool operations before operating any machine or power tool. It is the primary purpose of supervision to ensure that workers are following safe machine or power tool operating procedures. All machinery and equipment and power tools must be kept clean and properly maintained. There must be sufficient clearance provided around and between machines or power tools to allow for safe operations, set up, servicing, material handling, and waste removal. There must be a power shut-off switch within reach of the operator's position at each machine or power tool. Electrical power to each machine or power tool shall be capable of being locked out for maintenance, repair, or security. The non-current carrying metal parts of electrically operated tools must be grounded. All manually operated valves and switches controlling the operation of equipment and machines must be clearly identified and readily accessible. Portable Power Tools Portable power tools pose a special danger to workers because they are small and light, yet they can do great bodily harm if used improperly or poorly maintained. These rules apply to all power tools, but are 64 especially important when handling portable saws, drills, and power screwdrivers. Check your equipment before you use it. All grinders, saws, and similar equipment should be equipped with appropriate safety guards as provided in 29 CFR 1910.215. Power tools should not be used without the correct shield, guard, or attachment, recommended by the manufacturer. Portable circular saws must be equipped with guards above and below the base shoe. Circular saw guards should be checked periodically and before each use to assure they are not wedged up, thus leaving the lower portion of the blade unguarded. All rotating or moving parts of equipment should be guarded to prevent physical contact. All cord-connected, electrically operated tools and equipment should be effectively grounded or of the approved double insulated type. Effective guards must be in place over belts, pulleys, chains, sprockets, on equipment such as concrete mixers, air compressors, etc. If portable fans are provided, they must be equipped with full guards or screens having openings 1/2 inch or less. Do not attempt to lift heavy objects without proper equipment. Hoisting equipment will be made available for lifting heavy objects, with hoist ratings and characteristics appropriate for the task. Power tools are either battery- operated or wired. If battery operated, don't under-estimate their power. A small electric drill or power screwdriver can cause a severe injury if it lands in the wrong place. While not usually a shock hazard, the battery pack contains toxic chemicals and does emit a low voltage electric current. Don't drop or incinerate the battery pack, or a tool with a self-contained power source. Hard-wired equipment can be portable or fixed. Typically used with extension cords, the more powerful hard-wired equipment presents a double safety problem: the actual equipment plus its electrical power source. Ground-fault circuit interrupters must be provided on all temporary electrical 15 and 20 ampere circuits used during periods of construction. Pneumatic and hydraulic hoses on power-operated tools should be checked regularly for deterioration or damage. All power tools shall be used in compliance with appropriate NEC codes. 65 Section 18 MACHINE GUARDING I. Purpose The purpose of this section is to provide guidance on the minimum safety requirements related to machine safeguards which are used to protect employees when the operation of machines/equipment or accidental contact with it could cause an injury. II. Scope The program applies to all Laramie employees and contractors who work in areas where potential exposures to any machine where parts, functions, or processes may cause an injury. III. Definitions Device. A press control or attachment that restrains the operator from inadvertently reaching into the point of operation. Enclosure. Guarding by fixed physical barriers that are either mounted on or around the moving parts of the machine/equipment. Fencing. A locked fence or rail enclosure that restricts access to the machine, except by authorized personnel. The dangerous operation of the machinery must be at least 42 inches away from the fencing. Guard. A barrier (fixed or movable) that prevents contact with moving parts. Guards are more protective and are preferred over devices. Hazards. A source of potential harm or damage, or a situation with potential for harm or damage. In-going Nip Points. Two or more mechanical components rotating in opposite directions in the same plane and in close conjunction or interaction. Pinch Point. Any place where a body part can be caught between two or more moving parts. Point-of-operation. The point at which cutting, shaping, boring, forming, or processing is accomplished on or within the equipment. IV. Responsibilities A. Safety Department a. Ensure that program and associated documentation is completed and maintained. 66 b. Develops training materials and trains employees on the topics required by this program. c. Reviews the effectiveness of the program to make sure it satisfies the requirements of all applicable federal, state, or local requirements. d. Assists with or completes assessments and inspections, when required. B. Field Supervisors a. Ensures workers follow safe work practices when working with or near machines. b. Ensures workers do not remove or operate machines without machine guards in-place. c. Ensures safe operating and maintenance procedures are current and are followed by workers. C. Employees and Contractors a. Operate machines with all safeguards in place and follow all applicable safety requirements (e.g., lockout/tagout) b. Understand hazards related to machines being worked with and proper safeguarding methods. c. Participates in all required training. V. General Requirements and Procedures A. Guards must be placed on machines to protect the operator(s) and other workers in the area from hazards such as those created by the point of operation, in-going nip points, rotating parts, moving belts, cutting teeth, flying chips/sparks, and any other parts that impact or shear. B. Safeguards must prevent contact, be secure, protect workers from falling objects, create no new hazards, create no interference, and allow for safe lubrication of equipment. C. Safeguarding methods: a. Guards – prevents entry i. Fixed – a barrier or enclosure that permits material to enter into the operation zone, but not the operator’s body or body parts. Fixed guards are not dependent upon moving parts to perform its intended function. ii. Interlocked – When guard is opened or removed, the tripping mechanism and/or power automatically shuts off or disengages, and the equipment cannot operate until the guard is back in place. iii. Adjustable – protects the operator by placing a barrier between dangerous areas and the operator. iv. Self-adjusting – the guard is automatic, and the opening is determined by the movement of parts of the equipment. b. Device – controls entry (may be used to replace or as supplement to guard) 67 i. Gate – a moveable barrier that protects the operator at the point of operation before the equipment can be started. ii. Presence sensing device – equipment is either stopped or the cycle will not start, if a hand or any part of the body is inadvertently placed into a dangerous area. iii. Safety trip controls – a quick means for deactivating the equipment in an emergency situation. iv. Two hand control/trip – prevent operator from reaching into the point of operation by requiring concurrent pressure of operator’s control buttons to activate the equipment. c. Additional Methods i. When guards or devices cannot be used, there are additional methods that can be used such as fencing, safe distance, safe opening, and safe position of controls. ii. These additional methods do not provide the same level of protection of guards or devices. They depend on specific procedures, work rules, training, and/or supervision to prevent entry into dangerous areas. VI. Equipment Maintenance A. All equipment must be properly maintained per the manufacturer’s and/or the equipment owner’s requirements. B. All Laramie employees and contractors shall follow lockout/tagout procedures for shutting down equipment prior to removing any safeguards or accessing any equipment where he/she could be exposed to hazardous moving parts. C. If maintenance requires testing or adjustment of equipment with it’s safeguards removed, equipment specific procedures should be developed and followed for performing the task(s) safely. D. After maintenance is complete, replace safeguards before equipment restart. VII. Training A. Employees who work with or may be exposed to machines/equipment which require safeguarding will receive classroom training to ensure he/she is familiar with safeguarding methods and hazards. B. Employees who work with specific equipment will receive on-the-job training for that equipment. C. Classroom training records will be maintained by the safety department. 68 VIII. Revision History The table below lists all changes made to this section since the implementation of the program: 69 Section 19 FIRE PREVENTION I. Purpose This section is to assist in the prevention of fire and explosions on Laramie worksites. II. Scope The purpose of this section is to establish safe work requirements for preventing fires and explosions and protecting workers if a fire or explosion occurs. These safe work requirements include identifying and controlling hazards and instituting fire protection requirements. III. Definitions Bonding – The act of causing two metallic conductive elements to be at the same voltage level (not necessarily the same voltage as earth). Combustible liquids – Any liquid having a flash point at or above 100° F. Combustible liquids shall be divided into two classes: Class II liquids shall include those with flash points at or above 100° F and below 140° F, except any mixture having components with flash points of 200° F or higher, the volume of which makes up 99% or more of the total volume of the mixture (e.g., diesel). Class III liquids shall include those with flash points at or above 140° F. Class III liquids are subdivided into two subclasses: Class IIIA liquids, which include liquids with flash points at or above 140° F and below 200° F, except any mixture having components with flash points of 200° F or higher, the total volume of which makes up 99% or more of the total volume of the mixture (e.g. phenol). Class IIIB liquids, which include liquids with flash points at or above 200° F (e.g., motor oil). When a combustible liquid is heated to within 30° F of its flash point, it shall be handled in accordance with the requirements for the next lower class of liquids. Combustible solids – Combustible solids include oil-soaked rags, trash, grasses, paper, wood, etc. Explosion – A rapid increase in volume and violent release of energy resulting from a rapid chemical reaction, usually resulting in the release of high temperatures and gases. Fire – A rapid, persistent chemical change that releases heat and light and is accompanied by flame, especially the exothermic oxidation of a combustible substance. 70 Fire classification – Classes of fires are listed: Class “A” fire - involves ordinary combustible materials such as paper, wood, cloth, and some rubber and plastic materials. Class “B” fire - involves flammable or combustible liquids, flammable gases, greases, and similar materials, and some rubber and plastic materials. Class “C” fire – involves energized electrical equipment where safety to the employee requires the use of electrically nonconductive extinguishing media. Class “D” fire – involves combustible metals such as magnesium, titanium, zirconium, sodium, lithium and potassium. Flammable liquid – Any liquid having a flash point below 100° F, except any mixture having components with flashpoints of 100° F or higher, the total of which make up 99% or more of the total volume of the mixture. Flammable liquids shall be known as Class I liquids. Class I liquids are listed below: Class IA shall include liquids having flash points below 73° F and having a boiling point below 100° F. (e.g., ethyl ether). Class IB shall include liquids having flash points below 73° F and having a boiling point at or above 100° F. (e.g., methanol and gasoline). Class IC shall include liquids having flash points at or above 73° F and below 100° F (e.g., propyl alcohol). Flash point is the basis for classification of flammable and combustible liquids because it is directly related to a liquid’s ability to generate vapor, i.e. it’s volatility. Since it is the vapor of the liquid, not the liquid itself that burns, vapor generation becomes the primary factor in determining a fire hazard. Grounding – The act of causing a metallic conductive element to be at the same voltage level as earth. Hazardous location – A location where concentrations of flammable gases, vapors, or dusts occur. Electrical installations at such locations shall be specifically designed and tested to ensure it does not initiate an explosion, due to arcing contacts or high surface temperature of equipment. Ignition source – Any process or event capable of causing a fire or explosion. Open flames, sparks, static electricity, and hot surfaces are all possible ignition sources. Incipient stage fire – A fire which is in the initial or beginning stage and which can be controlled or extinguished by portable fire extinguishers, Class II standpipe or small hose systems without the need for protective clothing or breathing apparatus. 71 Portable tank – A closed container having a liquid capacity over 60 US gallons and not intended for fixed installation. Safety can – An approved container of not more than 5-gallon capacity having a spring-closing lid and spout cover, and so designed that it will safely relieve internal pressure when subjected to fire exposure. IV. Responsibilities A. Responsible managers will ensure: a. Development, implementation, communication, evaluation, maintenance and improving this section and making it available to workers. b. Training and materials are provided as necessary to applicable workers. B. Employees are responsible for: a. Adhering to the requirements of this section. b. Following proper equipment lighting procedures. c. Identifying and managing ignition source controls, fire protection requirements and signage. d. Maintaining and properly using personal gas monitors, portable fire extinguishers, fixed fire suppression systems, containers and portable tanks, storage cabinets, etc. e. Following proper maintenance, inspection and testing schedules and duties. C. Contractors are responsible for: a. Adhering to the requirements of this section at Laramie sites. b. Identifying fire and explosion hazards through JSAs, SOPs, MOCs, and/or safety permits. c. Conducting work in accordance with appropriate SOPs and any site safety permits. d. Controlling fuel and ignition sources in accordance with regulations or requirements. e. Providing properly selected, inspected, and maintained fire extinguishers in accordance with site and job requirements. V. Procedures A. Gas Detection Systems – Gas detection systems are used to monitor the air for oxygen levels, hydrogen sulfide (H2S), LEL, and carbon monoxide (CO). Many of these gases are monitored to detect health hazards, however; these measurements also indicate the presence of fire and explosion hazards such as LEL. Gas detection systems can be fixed systems, built into a facility, or personal gas detection monitors which are worn as monitors on a person. Requirements for these two types of gas detection systems are given below. 72 1. Fixed gas detection and suppression systems – A fire suppression system (i.e. automatic sprinkler system, deluge system and detection system) may be used where determined necessary. These systems must be properly maintained and tested for proper operation. Fixed gas detection must not be used in lieu of portable gas monitors for periodic or continuous gas monitoring requirements associated with a Hot Work Permit. 2. Personal gas detection – Personal gas detection refers to portable quantitative equipment that is used to detect various gases. Personal monitors are designed to provide fast and reliable warnings against flammable gases, dangerous oxygen concentrations and toxins. Personal monitors shall be used in the following situations: • When required by another section (Hydrogen Sulfide, Hot Work, Confined Space, etc.) • When working in an area where hydrocarbon or toxic gases may be present. • When lighting heaters, flares, burners or other fired equipment. • When working in enclosed areas where carbon monoxide may be present. • When working in areas where dangerous concentrations of oxygen may be present. • In areas where concentration of HsS could exceed 10 ppm in a breathing zone with limited dilution ventilation where no fixed detection is provided. • During activities which may release H2S into the atmosphere in the immediate work area. Monitor requirements: Personal monitors must have an audible and vibrating alarm and concentration readout on the unit. Alarms must be set at or below the PEL. All monitors must be intrinsically safe or explosion proof and must be calibrated, zeroed, bump-tested and maintained per the manufacturer’s recommendations. Direct gas readings should be analyzed and evaluated as per the manufacturer’s instrument operating instructions. B. Fire brigades – It is recommended that the use of local fire protection districts or fire departments be used for facility fire protection requirements for fire brigades. If one is determined to be needed on site, 29CFR 1910.156 requirements must be followed. C. Portable fire extinguishers – Fire extinguishers must be available for use at all Laramie facilities. They must be fully charged, inspected, and operational. They must remain in their designated location unless they are being used for emergency response, maintenance or servicing. 1. Selecting and locating fire extinguishers • The type of fire extinguisher must be selected based on the type of fuel source, such as combustible solids or flammable liquids. Maximum distances to a fire 73 extinguisher must follows regulations outlined in CFR 190.157(d). (Class A – 75 feet, Class B, C and D – 50 feet). • Determine the number of fire extinguishers required to protect property by considering: area and arrangement of buildings, severity of hazard, potential classes of fires, distances between extinguishers, etc.) • Mount portable fire extinguishers in plants, compressor stations, and offices as follows: in a conspicuous location, free from obstructions, with a maximum of five feet from the floor to the top of the extinguisher, with signage reading “fire extinguisher” to identify the location. • All field company vehicles must have a 20-lb. minimum fire extinguisher installed in a readily accessible location. 2. Inspecting fire extinguishers • Inspect all extinguishers monthly and annually. Extinguishers that do not pass inspection shall be repaired per the manufacturer’s recommendation or permanently taken out of service. Monthly fire extinguisher inspections for vehicles will be recorded on the Vehicle Inspection Form. Inspections for field locations will be recorded on the individual fire extinguisher tags. • All fire extinguishers shall be inspected annually by a qualified, approved inspector. This inspection will include the extinguisher’s shell, gauge, hose and nozzle, weighing and retagging. All service, maintenance or hydrostatic testing shall also be documented and retained. • Hydrostatic testing – if an extinguisher has severe corrosion, the shell is damaged or other detrimental conditions exist, the unit will be removed from service, discarded or hydrostatic tested to ensure that the shell is in good condition. Only personnel with proper testing equipment and knowledge shall test the extinguishers. All fire extinguishers will be hydrostatically tested at intervals listed in 29CFR 1910.157 Table L-1. D. Wildfire equipment – Wildfire equipment requirements are normally based on fire restrictions or bans in the working area and fall under local jurisdiction (BLM, Forest Service, county, etc.). Laramie employees will comply with any requirements or restrictions set forth. E. Signage – Fire prevention signs shall be posted in conspicuous locations and kept in good condition. F. Combustible solids – As a fuel source, non-essential combustible solids (oil soaked rags, trash, grasses, paper, vegetation, combustible waste materials, spent spill containment/absorbent wastes, and contaminated filters) shall be properly removed from the work area. When possible, select non-flammable or non-combustible materials as an alternative to reduce the fire and explosion hazard. G. Storage 74 1. Containers and portable tanks – Those used for flammable and combustible liquids must meet the following requirements: • Containers and tanks must remain closed when not in use. • The size and type of container and tank must meet storage requirements in compliance with 29CFR1910.106(d)(2)(iii) Table H-12 and NFPA 30 Table 9.4.3 • Each portable tank shall be provided with one or more devices installed in the top with sufficient emergency venting capacity to limit internal pressure under fire exposure conditions. • Non-conductive portable tanks (plastic or fiberglass) shall be equipped and configured to eliminate any static discharge that may occur during the handling of flammable liquids. 2. Storage cabinets – must meet the following requirements: • The quantity of liquids stored in cabinets shall not exceed 60 gallons of Class I or II or 120 gallons of Class III. • Shall be labeled “Flammable” • Shall meet design criteria listed in 29CFR1910.106(d)(3)(ii). • Water reactive materials (e.g., sulfuric acid) shall not be stored in the same area with flammable liquids. 3. Outdoor storage – must meet the following requirements: • Maximum of 1100 gallons of flammable liquids may be kept in containers or portable tanks adjacent to buildings. • For quantities over 1100 gallons, a minimum distance of 10 feet shall be maintained between buildings and the nearest container or portable tank. • Storage areas shall be graded to divert possible spills away from buildings or other exposures or shall be barricaded. • Drains shall terminate at a safe location and shall be accessible to operation under fire conditions. H. Handling – The following requirements shall be followed when flammable and combustible liquids are drawn from or transferred into containers or tanks: • The location of the liquid transfer shall be separated from ignition sources. • Ventilation (natural or mechanical) should be adequate to maintain LEL below 10% in the work zone. • Proper bonding and grounding practices shall be followed. • Inside buildings, flammable and combustible liquids may only be transferred: through a closed pipe system, from safety cans, by means of device drawing through the top, or by gravity through an approved self-closing valve. 75 • Mechanical equipment shall be cleaned with only fire-safe solvents, which are classified as Class IIIA combustible liquids. Equipment must not be cleaned with gasoline or other flammable liquids. I. Ventilation - In enclosed areas or buildings with the potential for accumulation of flammable vapors and gases, adequate natural or artificial ventilation shall be maintained to prevent concentration from exceeding dangerous LEL levels. VI. Training A. Fire prevention training will be provided for employees to an awareness level. Training may include fire watch, hands-on fire extinguisher, as applicable, Hot Work, and atmospheric gas monitor operation. B. Training documentation will be kept by the safety department. VII. Revision History The table below lists all changes made to this section since the implementation of the program: 76 Section 20 CONTRACTOR MANAGEMENT CONTRACTOR MANAGEMENT I. Purpose II. Scope III. Definitions IV. Responsibilities V. Procedures VI. Training VII. Revision History 77 Section 21 EMERGENCY RESPONSE I. Purpose The purpose of this section is to ensure each employee and contractor of Laramie Energy is provided a safe working environment. The emergency response procedures have been developed to provide an organized plan of action to prepare and respond to major natural and human-caused emergencies that threaten operations. Laramie employees responding to emergencies will follow procedures and plans specified in the Emergency Action Plan. II. Scope The program applies to all Laramie employees and addresses emergencies affecting the continued operations. This section includes the following emergency plans. A. Shelter in Place Plan. This plan protects occupants in the event of a hazardous materials release in the community or for other scenarios when it would be safer to remain in the building. B. Office Emergency Plan. This plan contains procedures to keep employees and visitors safe at the office. The plan covers medical emergencies, fire, bomb threats and the handling of suspicious packages. C. Emergency Action Plan. This plan contains procedures to keep employees safe in the event of a hazardous condition or scenario while performing field operations. III. Definitions A. Emergency. Any incident, human-caused or natural, that requires responsive action to protect life, property and environment. B. Event. A planned, non-emergency activity. C. Natural Emergencies. Major fires, hurricanes, earthquakes, tornadoes, snow and severe weather. D. Human-Caused Emergencies. Hazardous chemical releases, civil disorders, riots, bombings, hostage situations, etc. IV. Responsibilities A. Responsible managers will ensure: a. Development and implementation of specific emergency programs. b. Employees are trained on emergency procedures. c. Exercises are conducted to evaluate the effectiveness of the emergency action plans; and 78 d. Maintenance of training records and documentation related to incidents and exercises. e. Emergency service organizations responding to an emergency will be advised of any area that may be contaminated by flammable or toxic gases, vapors or dusts or any other hazardous atmosphere which could endanger life. f. That all employees, contractors and/or emergency responders are provided with proper PPE before entering an incident location that may have the potential for hazardous conditions. g. Every shift must have at least two persons who have a current CPR certification. B. Employees are responsible for: a. Attending emergency training; b. Reporting potential emergency situations to their responsible manager; and c. Following emergency action plans as directed. V. Procedures A. Emergencies will be assessed by the responsible manager(s) and/or emergency personnel for size and the potential to cause injury and illness to employees. The appropriate emergency plan will be implemented based upon the nature and seriousness of the emergency. B. Exercises will be conducted annually to evaluate the effectiveness of the plans. C. Any time an emergency plan is implemented, whether it is for an actual emergency or an exercise, the response will be documented. The documentation will include the date, description of the scenario, actions taken or parts of the plan implemented, participants, and critique. The critique will identify what went well and what areas need improvement. Plans will be modified as necessary to correct deficiencies. VI. Training A. Records of all post-incident evaluation (actual emergencies or exercises) will be retained by the safety department. B. Written records will indicate the source of the training, the employees trained, a description of the training provided, and the date when the training occurred. C. All training records will be maintained by the safety department. 79 VII. Revision History The table below lists all changes made to this section since the implementation of the program: VIII. Supporting Documents A. Shelter in Place Plan B. Office Emergency Plan C. Emergency Action Plan D. Emergency Notification Chart 80 Section 22 OTHER TOPICS Other Topics as listed below: Cleanliness All work sites must be clean and orderly as required by 29 CFR 1910.22. All work surfaces must be kept dry or appropriate means taken to assure that surfaces are slip-resistant. Spills must be reported and cleaned up immediately. All combustible scrap, debris, and waste must be stored safely and removed promptly. Waste containers must be covered. Oily and paint soaked rags are combustible and should be discarded in sealable metal containers only. Rags with spent solvent must be properly disposed of. Compressed Gas Cylinders - Compressed gas cylinders should be regularly examined for obvious signs of defects, deep rusting, or leakage. Use care in handling and storing cylinders, safety valves, and relief valves to prevent damage. Precaution must be taken to prevent mixture of air or oxygen with flammable gases, except at a burner or in a standard torch. Only approved apparatus (torches, regulators, pressure-reducing valves, acetylene generators, manifolds) may be used. Cylinders must be kept away from sources of heat. It is prohibited to use cylinders as rollers or supports. Empty cylinders must be appropriately marked, their valves closed and valve-protection caps on. Cylinders, cylinder valves, couplings, regulators, hoses and apparatus must be kept free of oily or greasy substances. Care must be taken not to drop or strike cylinders. Unless secured on special trucks, all regulators must be removed and valve-protection caps put in place before moving cylinders. All cylinders without fixed hand wheels must have keys, handles, or non-adjustable wrenches on stem valves when in service. Liquefied gases must be stored and shipped valve-end up with valve covers in place. Stored cylinders shall be kept separate in “Used/Unused” sections and marked as such. Areas where cylinders are stored must be clearly marked with signs that read: DANGER - NO SMOKING, MATCHES, OR OPEN FLAMES/LIGHTS Regulators and Hoses - Before a regulator is removed, the valve must be closed and gas released from the regulator. All workers are instructed never to crack a fuel-gas cylinder valve near sources of ignition. Gas hoses shall be color-coded: • Red for acetylene (and other fuel-gas); • Green for oxygen hose, and • Black for inert gas and air hose. All pressure-reducing regulators must be used only for the gas and pressures for which they are intended. Liquids Handling and Transfer Operations Liquids handling and transfer operations occur on a regular basis for condensate and produced water. Laramie Energy retains competent contractors to complete these activities and the companies providing 81 these services are required to develop and maintain their own corporate safety programs and procedures. At a minimum, Laramie Energy requires: • All drivers must comply with DOT regulations in 49 CFR Part 177 and facility standard operating procedures posted at the facility; and • Drivers must be authorized by Laramie Energy to load or unload product at any facility; • No smoking during liquids transfer operations. • Drivers must park their vehicle upwind or cross wind of the tank containing the liquids. • The vehicle must be grounded and turned off during liquids transfer operations. • The use of drip pans under hose connections is required. In addition, drivers must observe the requirements of the SPCC plan. Fueling Fueling and refueling operations are not common activities during the operation of a natural gas field, except where power equipment, generators, or similar equipment are temporarily in use. Workers involved with fueling activities must be trained in proper handling and storage of flammable liquids, how to operate and shut off the fueling system and in spill response operations. The applicable Spill Prevention, Control and Countermeasures Plan should be reviewed by all personnel involved with fueling operations. Pipelines and Gathering Systems All pipelines must be constructed and maintained in accordance with the standard for interstate pipeline regulations. The location of all buried pipelines must be clearly marked and signs must be posted identifying the pipeline contents, the potential hazards (i.e. high pressure, toxicity or flammable) and where turn-off valves, connections and outlets are located. All tags used for labeling will be of a durable material with distinguishable and clearly written print. When non-potable water is piped through a facility’s outlets or taps, notices will be posted to alert workers that it is unsafe and not to be used for drinking, washing or personal use. Well Drilling and Completion Operations Laramie Energy retains independent professional contractors for all services related to well drilling from initial staking through drilling, completion and hook-up. These contractors are fully competent and trained and they maintain their own corporate safety programs and procedures. All contractors are responsible for the implementation and enforcement of their own safety policies and procedures. Laramie Energy fully supports those measures. Even so, Laramie Energy feels that supplemental safety policies, complementary to the contractor’s regulations in place, are warranted. The following section summarizes the Company’s policies concerning well drilling, well completion and well workover activities. 4.3.1 General Drilling Safety Spudding shall not commence until all guards are in place on all equipment to be operated; all platforms, stairways, and handrails are secured in position; the escape line with buggy is installed; and 82 A-leg pins are instead in their proper A-leg holes and secured by safety pins to prevent their displacement. An escape line shall be a wire rope of suitable diameter and type. It shall be kept free of obstructions. An approved safety buggy with an adequate braking device (Geronimo) shall be installed on the escape line and kept at the derrick man’s working platform. The safety buggy and escape line shall be checked by the derrick man each trip. Tension on the escape line shall be such that a 200- pound worker sitting in the safety buggy will touch the ground at least twenty feet (20') from the anchor. The minimum length of the escape line, which shall be securely anchored both at the ground and to the rig, shall be adequate to assure no less than 45-degree descent from the vertical plane. OSHA safety regulations that address common drilling-related safety concerns include: • 29 CFR 1910.23 – Floor openings; • 29 CFR 1910.24 – Guarding of Stairs; • 29 CFR 1910.27 – Ladders and Climbing Devices; • 20 CFR 1910.132 - Hazard Assessment; and • 29 CFR 1910.132 - Fall Protection Devices and Rescue Plans; • 29 CFR 1910.184 - Slings and Lifting Devices. Every person, when engaged in work at ten feet (10') or more above the derrick floor or other working surfaces, shall wear a safety harness with an attached safety line secured to the derrick except during rig up and rig down. Where these regulations prescribe the use of safety harness, the operator shall use an approved safety harness suitable for the particular job and in good condition, which safety harness and lifeline is to be provided by the employer. The safety harness shall be attached by means of a tail rope or lanyard to a fixed anchor and adjusted to allow the minimum of drop in case of fall. A separate lifeline shall be provided for each operator requiring a life line, and safety belts and life lines shall be checked before each use and maintained in good condition. Every automatic cat head shall have a separate control. Where dual-purpose controls are used, a positive locking device shall be installed to prevent one automatic cat head from accidentally engaging while the other is in operation. When practical, draw works master controls shall be effectively locked out when not in use. Guards shall be installed so that controls may not be accidentally engaged through contract by cat lines or other equipment. The engine room, pump house, derrick floor and fourble board shall be enclosed to a sufficient height to provide protection against inclement weather. Exits shall be provided to the outside on at least three sides of the derrick floor. The pump house shall have two doors leading in different directions to the outside. No exit door of a derrick, including all doors of the doghouse, shall be held closed with a lock or outside latch while anyone is on the derrick floor. The suction pit or tanks used for the circulation of flammable materials shall not be located inside the pump house. No operator shall handle a traveling hoisting line unless he uses a suitable hand guard, which shall be secured to the derrick. No operator shall slide down any pipe, kelly hose, cable, or rope line except in the event of an extreme emergency. No operator shall ride a traveling block with which pipe is being moved at any time. When riding a traveling block or elevators, a safety belt with lanyard shall be worn and the lanyard shall be attached to the block above the hook. No operator shall use the cat line as a means of ascending to or descending from any point in the derrick except in an emergency. Even then the rotary table shall be locked out and qualified workers shall operate the cat head and controls. 83 When working on hydraulic tong heads, the input pressure line shall be disconnected. High pressure lines (hydraulic or air) shall have a safety pressure relief valve which shall never be set higher than manufacturer's specifications for the working pressure of the lines or valve. Hydraulic tongs shall be backed up with a safety device able to withstand the full torque of the power tool. Auxiliary power tong units which employ internal combustion engines shall have the power unit placed seventy-five feet (75') upwind of the well bore, considering the normal prevailing wind at the rig location, where location and terrain permit. The rotary table shall not be used for the final making up or initial breaking out of a pipe connection. All pipe and drill collars racked in a derrick shall be secured with rope or otherwise adequately secured to prevent them from falling across the derrick. Safety clamps, used on drill collars, flush joint pipe, or similar equipment for the purpose of preventing its falling in the well when not held by the elevator, shall be removed from the drill collars, pipe, or similar equipment before being hoisted up into the derrick. Racking foundations shall be designed to withstand the load or racked pipe and drill collars and be secured to prevent turnover. 4.3.2 General Drilling Rules Surface casing shall be run to reach a depth to prevent blowouts or uncontrolled wells. In areas where pressures and formations are unknown, surface casing shall be of sufficient size to permit the use of an intermediate string or strings of casing. Surface casing shall be set in or through an impervious formation and shall be cemented by the pump and plug or displacement or other approved method with sufficient cement to fill annulus to the top of the hole. If cement is not circulated to the surface during the primary operation, supplemental cemented operations shall be performed to assure that the annular space from the casing shoe to the surface is filled with cement. The cemented casing string shall stand under pressure until the cement has reached a compressive strength of 300 pounds per square inch; providing, however, that no further operation shall be commenced until the cement has been in place for at least eight (8) hours. The term "under pressure" as used herein shall be complied with if one float valve is used or if pressure is otherwise held. Setting depths of all casing strings shall be determined by taking into account formation fracture gradients and the maximum anticipated pressure to be maintained within the well bore. If and when it becomes necessary to run a production string, such string shall be cemented by the pump and plug method and shall be properly tested by the pressure method before cement plugs are drilled. Natural gas which may be encountered in a substantial quantity in any section of a cable tool drilled hole above the ultimate objective shall be shut off with reasonable diligence either by mudding or casing, or other approved method and confined to its original source. Any gas escaping from the well during drilling operations shall be, as far as practicable, conducted to a safe distance from the well site and burned. An approved safety harness (as provided in 29 CFR 1910.66) suitable for the particular job or hazard exposure, which shall be attached by means of a tail-rope or lanyard to a fixed anchor and adjusted to allow the minimum of drop in case of a fall, shall be provided and worn. Every person, when engaged in work at ten feet (10') or more above the derrick floor or other working surfaces, shall wear a safety belt with an attached safety line secured to a fixed point, or be supported from the tugger line by a safety harness or tree trimmer-type belt. The tugger line shall not be freewheeling. Special protective wearing 84 apparel shall be provided and worn as deemed necessary because of unusually hazardous situations not normal to the job. 4.3.3 Blowout Equipment Blowout prevention equipment (BOP) in all drilling operations shall be in accordance with recognized safe practices, reasonably adequate to keep the well under control at all times, as well as inclusive of blowout preventers, choke and kill lines, as necessary, and maintained in good working condition at all times. One or more workers employed on the rig shall have an adequate understanding of, and be able to operate, the blowout preventer system. At least one person who is trained in blowout prevention and well control procedures shall be on the well site. Blowout preventer controls shall be readily accessible on the floor and/or at least twenty feet (20') from the well bore and outside the substructure. All blowout preventers, choke lines and manifold shall be installed above ground level. Casing heads and optional spools may be installed below ground level provided they are visible and accessible. All pipe fittings and valves placed on, or connected with a blowout preventer, well casing, casing head, or the drill pipe or tubing, shall be of a type suitable for the purpose for which they are to be used and adequate to withstand the pressure which may be encountered. All ram type blowout preventers and related equipment, including casing, shall be tested to the full working pressure rating of said equipment upon installation, provided that components need not be tested to levels higher than the lowest working pressure rated component. Annular type blowout preventers shall be tested in conformance with the manufacturer's recommendations. If, for any reason, a pressure seal in the assembly is disassembled, a test to a full working pressure rating of that seal shall be conducted prior to the resumption of any drilling operation. In addition to the initial pressure tests, ram type preventers shall be checked for physical operation each trip and all components, again with exception of the annular type blowout preventer, tested monthly to at least fifty percent (50%) of the rated pressure of the blowout preventer equipment and/or to the maximum anticipated pressure of the blowout preventer equipment and/or to the maximum anticipated pressure to be contained at the surface, whichever is greater. The working pressure rating of all blowout preventers and related equipment shall equal or exceed the maximum anticipated pressure to be contained at the surface. The entire blowout preventer and wellhead assembly shall be kept reasonably clean of mud and ice. Studs on all wellhead and blowout preventer flanges shall be checked weekly for tightness. Where locking screws are provided on blowout preventers, hand wheels shall be kept installed and operational, and readily accessible. A drill stem safety valve shall be available on the rig floor at all times. While a well is being drilled, tested, completed, or reconditioned, the appropriate blowout equipment shall be mechanically tested periodically, and the blind rams shall be mechanically tested daily (provided that this requirement does not necessitate a special trip of the tools from the hole). If found defective, any such equipment or rams shall be made serviceable before operations are resumed. All tests shall be documented in the daily drilling logbook, and in the case of a pressure test, the pressure applied and the duration shall be recorded. BOP equipment installed on wells in which formation pressures to be encountered are abnormal or unknown shall consist of a double-gate, hydraulically operated preventer with pipe and blind rams or two single-ram type preventers, one equipped with pipe rams, the other with blind rams and an annular 85 type preventer. In addition, upper and lower kelly cocks, pit level indicators with alarms and/or flow sensors with alarms, and surface facilities to handle pressure kicks shall be installed prior to drilling any formation with known abnormal pressure. Accumulators shall maintain a pressure capacity reserve at all times to provide for operation of the hydraulic preventer and valves with no outside source. Areas in which abnormal pressures are likely to be encountered are those as defined by the Oil and Gas Conservation Commission's staff and posted on a map to be available in the State Oil and Gas Supervisor's office. This map, to be updated as information becomes available, will also segregate, vertically, formations where abnormal pressures are likely to be encountered. In all other drilling operations, BOP equipment shall consist of at least one double-gate preventer with pipe and blind rams or two single-ram type preventers, one equipped with pipe rams, the other with blind rams, and sufficient valving to permit fluid circulation at the surface, or shall be as approved by the State Oil and Gas Supervisor's Office and/or the U.S. Geological Survey District Engineer's office, as filed on the drilling permit. Blowout preventer equipment and related casing heads and spools shall have a vertical bore no smaller than the inside diameter of the casing to which they are attached. 4.3.4 Mud Pits and Tanks Portable tanks shall be located where it is not possible for workers or equipment to come into contact with overhead power lines. All discharge lines shall be properly secured. No operator shall jump from one tank top to another. All fixed mud guns used for jetting shall be pinned or hobbled when unattended. Hoses used for jetting operations shall be manned and an operator stationed at the pump control to shut down the pressure in the event of an emergency. Standard railings shall be provided on the inside of all mud tank walkways. Where such walkways are four feet or more above ground level, both sides shall be provided with standard railings. ") XY Gate 12 25 36 13 25 01 01 24 01 12 13 12 24 6S 97W 7S 97W Mile 1 Mile 2 Mile 3 Mile 4 Mile 5 Mile 6 Mile 7 Mile 8 Mile 9 Mile 10 Mile 11 3 40" 24" 24" 18" 24"24" 2 24" 24"24" 24" 24" 18" 24" 24" 24" 24" 24" 24" 24" 24" 24" 24" 24" 24" 24" 18" 18" 24" 24" 18"12" 24" 24" 16" 24" 12" 24" 36"36" 24" 16" 16" 24" 24"24" 24" 16" 18" 3 30" 54" 16"COUNTYRD213CC 610-21-41 06 35 29 14 21 33 04 03 28 11 03 31 34 20 27 1109 32 02 07 08 10 16 0907 04 06 10 05 18 08 19 22 02 15 05 26 23 17 30 Copyright:© 2013 National Geographic Society, i-cubed Document Path: L:\GIS\GIS_Staging\Landmapping_2021\Landmaps_21\CC_OGDP_A1_Access2_.mxdMile Markers, Private Road Existing Private Access Road 2000' Access Road Buffer Proposed Access Road Public Road Culverts ")OGDP Sites Proposed Working Pad Surface OGDP Application Lands Laramie Owned Surface Parcels_GarCo Date: 11/10/2021 0 1 20.5 Miles ± At this gate traffic entersLaramie's private property Existing Private Access Road OGDP ACCESS ROAD - CC 610-21-41 PADLARAMIE ENERGY, LLC Township 6S, Range 97W, 6th P.M.Section 10: NENW Garfield County, Colo. CC 0610-21-41 Pad Minor Temporary Employee Housing Garfield County, Colorado Table of Contents Housing Documents 1.Civeo Scope of Work2.Redi Services Potable Water Hauling and Sampling3.Wastewater Disposal Contract4.Building Floorplan5.Colorado Certified (Blue Tags) Photos6.Wastewater Pump Specifications7.Potable Water Pump Specifications Contacts: Fred Allison – Field Service Support Manager 3601 Stagecoach Rd Suite 101, Longmont CO 80504 TEL: 970-623-3499 MOB: 435-650-3636 Fred.Allison@civeo.com Scope of Work for Laramie’s CC 0610-21-41 Pad •To provide onsite Housing, Water, Sewer, and Surface Equipment. •Civeo contracts Redi Services West for Water Hauling of Potable Water. State ofColorado PWSID Permit # CO0252671 to operate as a potable water deliverysystem. Redi Services purchases water from the Town of Silt and Red Point LLC ofParachute. •We will provide three (3) climate controlled 3360 gallon potable water tanks. •Delivery of potable water twice a week or more if necessary. •Hauling of Gray Water " Sewer". We are permitted to haul and dispose of gray waterto the City of Rifle and Clifton Sanitation District. •We will provide four (4) climate controlled 1800 gallon waste water storage tanks. •Pick up of wastewater twice a week or more if necessary. •The waste water demand calculation will be 75 gallons per day, per person. Best, Fred Allison Fred Allison Field Service Support Manager - Civeo Corporation Public Water System ID Water System Name Federal System Type State Source Type Service Connections Population CO0252671 REDI SERVICES WEST Non-Transient, Non-Community Purchased Surface Water 2 115 Primary County Minimum Certification for Treatment Operator Minimum Certification for Distribution System Operator Last Inspection Seasonal Water Hauler RIO BLANCO No Requirement 1 05/07/2021 No Yes REDI SERVICES WEST Calendar Year 2022 Monitoring Schedule Mailing Address: PO BOX 273119 FORT COLLINS, CO 80527 General Information *Samples must be collected at the location specified in the Monitoring Plan or Record of Approved Waterworks.* •Schedules are updated every Wednesday evening. Please contact your specialist with questions wqcdcompliance.com or call us at 303-692-3556. •System info, online records, public notices, violations, and sample results (bottom of page). •Laboratory sample results must be analyzed by a certified laboratory using a certified method. The requirements listed below are the minumum. Additional sample results (i.e. any and all) collected at a compliance sampling location and analyzed by a certified laboratory using a certified method must be submitted using the Online Portal wqcdcompliance.com/login, fax, or mail. •Please identify the Facility ID and Sample Point ID (listed below) when submitting sample results. Facility and Sample Point IDs are used to identify general sample site locations. Monitoring Information Distribution System Sample Schedules Facility ID DS001 Facility Name DISTRIBUTION SYSTEM Facility Type Distribution System Microorganisms and Disinfectants TOTAL COLIFORM BACTERIA (TCR) Sample Schedule: Collection Period: 2 sample(s) per Month during the collection period January 1, 2022 to December 31, 2022 Use the Facility ID and Sample Point ID listed at the end of this monitoring schedule. FREE CHLORINE Sample Schedule: Measure every time you collect a TOTAL COLIFORM BACTERIA (TCR) sample Contact Information All public water systems are required to maintain an Administrative Contact, Treatment Operator (if applicable), Distribution System Operator (if applicable), and Owner. If the information below is incorrect or blank please send us a contact update form. This form and operator certification information is available by visiting wqcdcompliance.com/forms. Administrative Contact Treatment Operator Distribution System Operator Owner VANESSA MANCILL RONALD TORRES JR CLINT CONDOS 2022 Monitoring Schedule Page 1 of 3PWS ID: CO0252671 REDI SERVICES WEST Report Generation Date: March 23, 2022 This monitoring schedule is based on the system's current inventory and is subject to change. Water systems are responsible for promptly reporting schedule errors or omissions. Errors or omissions on monitoring schedules do not prohibit the Water Quality Control Division from enforcing monitoring requirements set forth by the Regulations. Facility Specific Levels Facility ID DS001 Facility Name DISTRIBUTION SYSTEM Facility Type Distribution System Analyte Name Level Level Type FREE CHLORINE 0.2 mg/L Minimum FREE CHLORINE 4.0 mg/L Maximum Facility Information Sample Point Information Facility ID Active Status Facility Name Facility Type Sample Point ID Sample Point Name 001 A PURCHASED MEEKER CO0152505 Non-Piped, Purchased 001 PURCHASED 007 A PURCHASED WATER FRM CO0123602 PARACHUTE Non-Piped, Purchased 007 PURCHASED 009 A WATER HAULER TRUCK RIFLE 3018 Storage 009 DIST TANK 010 A WATER HAULER TRUCK RIFLE 3088 Storage 010 DIST TANK DS001 A DISTRIBUTION SYSTEM Dist System/Zone DBP001 TANK OUTLET RPOR REPEAT ORIGINAL RPOT REPEAT OTHER RTOR ROUTINE ORIGINAL 002 I PUCHASED CITY OF SILT CO0123710 Non-Piped, Purchased NO ACTIVE SAMPLING POINT NO ACTIVE SAMPLING POINT Backflow Prevention and Cross-connection Control (BPCCC) Reminders: •Annual BPCCC Reports need to be completed by May 1, 2022 for activities completed in 2021. •The required survey compliance ratio for 2021 is 1.0, unless you have a CDPHE approved alternate ratio. •The required assembly testing ratio for 2021 is 0.90 and the required method inspection ratio is 0.90. •Annual BPCCC reports should only be submitted to us if a violation occurred. Reports and supporting calculations will be reviewed during your next sanitary survey, however, we can request this information at any time. •All assemblies and methods not tested/inspected in 2021 must be tested/inspected within 90 days of the active date in 2022. The active date is the first day that water flows through the assembly or method. •The required survey compliance ratio for 2022 and each year after is 1.0. •The required assembly testing ratio and method inspection ratio for 2022 and each year after is 0.90. •For more information regarding the requirements and how to compile a report please visit wqcdcompliance.com/forms or submit specific questions to cdphe_wqcd_fss_questions@state.co.us. Storage Tank Reminders: All storage tanks within the distribution must be inspected twice per year unless an alternative storage tank inspection schedule has been established and included in the written inspection plan. An alternative storage tank inspection schedule is subject to our review and revision, generally during a sanitary survey, but alternative inspection schedules can be requested by us at any time. All storage tanks within the distribution are required to undergo a comprehensive tank inspection every five years. The first five year cycle for completion of comprehensive tank inspections is due by the end of 2021. 2022 Monitoring Schedule Page 2 of 3PWS ID: CO0252671 REDI SERVICES WEST Report Generation Date: March 23, 2022 This monitoring schedule is based on the system's current inventory and is subject to change. Water systems are responsible for promptly reporting schedule errors or omissions. Errors or omissions on monitoring schedules do not prohibit the Water Quality Control Division from enforcing monitoring requirements set forth by the Regulations. Time Period Definitions Time Period Start Date End Date First Quarter January 1, 2022 March 31, 2022 Second Quarter April 1, 2022 June 30, 2022 Third Quarter July 1, 2022 September 30, 2022 Fourth Quarter October 1, 2022 December 31, 2022 First 6 Months January 1, 2022 June 30, 2022 Second 6 Months July 1, 2022 December 31, 2022 Year January 1, 2022 December 31, 2022 003 I WATER HAULER TANK TRUCK WYOMING A7773 Storage 003 ENTRY POINT 004 I WATER HAULER TANK TRUCK WYOMING A6878 Storage 004 DIST TANK 005 I WATER HAULER TRAILER TL6 Storage 005 DIST TANK 006 I WATER HAULER TANK 349 BOBTAIL SKID Storage 006 DIST TANK 008 I PURCHASED TOWN OF FREDERICK CO0162288 Non-Piped, Purchased NO ACTIVE SAMPLING POINT NO ACTIVE SAMPLING POINT Lead and Copper Sample Pool Information The supplier must collect lead and copper samples from different Department - approved sample sites below until the minimum number of samples required is collected. Contact your compliance specialist if there are questions about unapproved sites. The supplier can add, manage, or inactivate unavailable sample sites on the Data Portal at wqcdcompliance.com/login under My…Sample Sites. Sites have been grouped by sampling priority based on tier level: •If present, Tier 1 sites must be sampled unless reported as an unavailable high risk site. •If present, Tier 2 sites must only be sampled after all Tier 1 sites have been sampled or have been reported as an unavailable high risk site. •If present, Tier 3 sites must only be sampled after all Tier 1 and 2 sites have been sampled or have been reported as an unavailable high risk site. •If present, Non-Tier, Representative sites must only be sampled after all Tier 1, 2, and 3 sites have been sampled or have been reported as an unavailable high risk site. Unavailable high risk site reporting form is available at wqcdcompliance.com/lcr NO TIER 1 - HIGHEST RISK SITES HAVE BEEN IDENTIFIED NO TIER 2 - SECOND HIGHEST RISK SITES HAVE BEEN IDENTIFIED NO TIER 3 - THIRD HIGHEST RISK SITES HAVE BEEN IDENTIFIED NO NON-TIER, REPRESENTATIVE - FOURTH HIGHEST RISK SITES HAVE BEEN IDENTIFIED 2022 Monitoring Schedule Page 3 of 3PWS ID: CO0252671 REDI SERVICES WEST Report Generation Date: March 23, 2022 This monitoring schedule is based on the system's current inventory and is subject to change. Water systems are responsible for promptly reporting schedule errors or omissions. Errors or omissions on monitoring schedules do not prohibit the Water Quality Control Division from enforcing monitoring requirements set forth by the Regulations. Clifton Sanitation District Wastewater Discharge Permit In compliance with the provisions of the Rules and Regulations of the Clifton Sanitation District, herein referred to as the District, Civeo Corporation (herein referred to as the "Permittee") whose facility is located at 3601 Stage Coach Rd., Suite 101, Longmont, CO 80504 with a mailing address of same is authorized to discharge to the sanitary sewer system in accordance with the effluent limitations, monitoring requirements and other conditions as set forth herein and in the Waste Hauler Agreement No. 01-18-001. This permit shall become effective on March , 2021. This permit shall expire at midnight March , 2023. If the Permittee desires to discharge after the expiration date, the Permit tee shall request a permit application form from the District within 90 days of expiration of this permit. The application shall be submitted to the District within 30 days of receipt of the permit application form by the Permittee. This permit is not transferable. All reports and notifications required by this permit and the District’s Rules and Regulations shall be made to the address and telephone number below: Clifton Sanitation District Eli Jennings, District Manager 3217 D Road Clifton, CO 81520 (970) 434-7422 Signed this day of March, 2021. ______________________________ Eli Jennings District Manager Receipt of this Wastewater Discharge Permit is hereby acknowledged by: ______________________________ _____________ Authorized Representative of the Permittee Date Print Name 1 1 1 March 1, 2021 Fred Allison Fred Allison Eli Jennings 2 I.OUTFALL AND WASTE DESCRIPTION Outfall Description and Location 001 The discharge shall be made at 3217 D Road at the location and time directed by District staff. Waste Description: The Permittee is authorized to discharge wastewater that is solely domestic waste. The domestic waste is generated from the temporary living quarters of gas and oil field personnel. The wastewater is generated through the use of showers, sinks, toilets and washing machines. It is collected on site in a holding tank that is pumped by the Permittee and brought to the discharge location. II.EFFLUENT MONITORING AND LIMITATIONS A.Dilution Prohibition The Permittee shall not increase the use of clean water or process water or, in any way, attempt to dilute a discharge as a partial or complete substitute for adequate treatment to achieve compliance with any applicable limitation, standard or requirement. B.Specific Effluent Limitations 1.Effective immediately, the Permittee shall not discharge wastewater containing any of the materials and substances in excess of the concentrations listed in the Table below. The Permittee shall monitor at the frequency shown. 3 Outfall 001 (all concentrations, unless noted, are Total mg/L) Pollutant Daily Maximum Limit Monitoring Frequency (2) Sample Type (2) Arsenic (As) -- Quarterly Composite Cadmium (Cd) -- Quarterly Composite Chromium (Cr) (4) -- Quarterly Composite Chromium (VI)(4) -- Quarterly Grab Copper (Cu) -- Quarterly Composite Lead (Pb) -- Quarterly Composite Mercury (Hg) -- Quarterly Composite Molybdenum (Mo) -- Quarterly Composite Nickel (Ni) -- Quarterly Composite Selenium (Se) -- Quarterly Composite Silver (Ag) -- Quarterly Composite Zinc (Zn) -- Quarterly Composite Benzene 0.05 mg/L Quarterly Grab BTEX (3) 0.75 mg/L Quarterly Grab Oil and Grease -- Quarterly Composite Visual (2) -- 1 per Truck Load Grab Volume (gpd) 16,000 Each Truck Load Total pH, Standard Units (1) ≥5.5 and <12.5 Each Truck Load Grab (1) Any pH discharge greater than or equal to 12.5 is subject to the hazardous waste reporting criteria required by 40CFR Section 403.12(p) and Section 5.16(e) of the District’s Rules and Regulations. (2) See Special Notes in paragraph 2 below. (3) BTEX is the sum of Benzene, Toluene, Ethylbenzene and Xylenes. (4) If the Chromium (Total) measurement exceeds 0.011 mg/L, the Permittee shall sample for Chromium (VI) until the District notifies the Permittee, in writing, that it may discontinue sampling and return to sampling for only Chromium (Total). The Chronic Water Quality Standard for Chromium (VI) is 0.011 mg/L and this value is used as the trigger in this Permit. 40 CFR Part 136 establishes specific requirements for sampling, preservation and analysis for Chromium (VI). 2. Special Notes: (a) Metals and Oil and Grease: A composite sample shall be collected by taking a grab sample at the beginning, middle and end of the discharge and combining into one sample. (b) Benzene and BTEX: A sample shall be taken during the discharge of wastewater from the tank on the truck. 4 (c) pH and Visual Observation: A grab sample shall be collected during discharge of wastewater from the truck for pH measurement and visual observation. (d) The permittee shall sample each truck load. All visual observations and pH measurements shall be recorded by the permittee into a log and kept on site. 3. The District Manager may establish more stringent pollutant limits, additional site-specific pollutant limits or Best Management Practices (BMPs) when, in the judgment of the District Manager, such limitations are necessary to implement the provision of the District’s Rules and Regulations. 4. The Permittee is advised that definitions applying to this permit are provided for in Article 5 of the District’s Rules and Regulations. 5. The Permittee shall utilize a manifest that is approved by the District for all wastewater that is delivered to the discharge location. 6. The District shall collect all samples and perform all measurements required under Section II.B. of this Permit. The Permittee shall complete and submit manifests for each load as required by Section II.B.5. of this Permit. In the event that the District no longer opts to collect samples in lieu of the Permittee, the Permittee shall be responsible for all sampling and reporting requirements under this Permit. C. Specific Storm Sewer Discharge Prohibitions Effective immediately, the Permittee shall not discharge or cause to be discharged to a storm drainage facility any material that is not entirely composed of storm water. The discharge of process and domestic wastewaters to the storm sewer is prohibited. III. SELF-MONITORING A. Sampling and Analyses Except as specified in Section II.B.6. of this Permit, the Permittee is required to perform collection and analyses of wastewater samples with the frequency and type of measurement indicated in Section II, B of this permit. Samples or measurements shall be representative of the discharge during the sampling period, representative of normal operating conditions and shall be taken as required. Additional Monitoring to be reported: Results of all additional samples if analyzed by test procedures approved under 40 CFR Part 136, must be submitted as part of the required reports during the reporting period. 5 Equipment or instrumentation used for self-monitoring must be maintained in good working order and calibrated according to the manufacturer’s specifications. Maintenance and calibration records must be kept on site and available for inspection. B. Violation of Pollutant Limits A violation of any pollutant limit must be reported to the District within twenty-four (24) hours of: 1. The Permittee's receipt of analytical data from an outside lab; or 2. The result being available to the Permittee when the analysis is performed in- house. If any sample shows a violation, the permittee shall collect additional samples and analyze for the pollutant parameter(s) that showed the violation. The permittee shall continue this resampling effort on 10 consecutive truck loads delivered for disposal. The sample results shall be submitted to the District within thirty (30) days of becoming aware of the violation. The Permittee shall report all instances of a truck load being rejected or turned away. A report of the reason(s) for rejection shall be submitted with the required report for that month. These reporting and resampling requirements are not required for samples and measurements taken by the District in accordance with Section II.B.6. of this Permit. C. Test Procedures and Monitoring Requirements All pollutant analysis, including sampling techniques, to be submitted as part of a wastewater discharge permit application, report, permit or other analysis required under this Permit or the District’s Sewer Use Regulations shall be performed in accordance with the techniques prescribed in 40 CFR Part 136 and amendments thereto, unless otherwise specified in an applicable categorical Pretreatment Standard. IV. REPORTING REQUIREMENTS A. Periodic Compliance Reporting Except for samples and measurements covered by Section II.B.6. of this Permit, compliance reports containing the following information shall be submitted monthly. The reports are due on or before the 28th of the month following the sampling period. The report must be received by the District at the address designated on Page 1 of this Permit. The first report is due on the 28th of the first month after the permit is signed. Reports shall include: 6 1. Concentrations and measurements of all parameters for which there are self-monitoring requirements. Legible copies of completed chain-of-custody (COC) forms and laboratory analytical reports for each sample shall be included. 2. A copy of all logs required for that month, including total volume accepted, results of all pH measurements, and the logs for the required visual observations. pH meters shall be calibrated and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. 3. Copies of any spills shall be maintained and reported. Information shall include the date, time, and estimated volume. The permittee shall also describe how the remediated spill was remediated. 4. The following certification statement: "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." 5. If no discharge occurs during the reporting period, "No Discharge" shall be reported. V. STANDARD CONDITIONS A. General and Specific Discharge Prohibitions The Permittee shall not introduce pollutants into the District’s POTW which may cause Pass Through or Interference or cause violations of any of the Specific Prohibitions specified in Section 5.9 of the District’s Rules and Regulations. B. Changes in Operation The Permittee shall file a notification to the District a minimum of fourteen (14) days prior to any planned significant change in operations or wastewater characteristics. A significant change shall be a change to, but is not limited to the following: 1. Change in number or type of trucks delivering waste. 2. Any change in the type of waste. The current permit is written to limit the type of waste discharged to the District is solely domestic waste from typical residential type sources. 7 C. Reports of Potential Problems 1. In the case of any discharge, including, but not limited to, accidental discharges, discharges of a nonroutine, episodic nature, a noncustomary batch discharge, a Slug Discharge or Slug Load, that might cause potential problems for the POTW, the User shall immediately telephone and notify the District Manager of the incident. This notification shall include: (a) Name of the caller (b) Date and time of discharge (c) Date and time discharge was halted (d) Estimated volume of discharge (e) Estimated concentration of discharge for any pollutant that may cause a problem (f) Corrective actions taken to halt the discharge (g) Method of alternative disposal if applicable 2. Within five (5) working days following such discharge, the Permittee shall submit a written report describing the cause(s) of the discharge and the measures to be taken by the Permittee to prevent similar future occurrences. Such notification shall not relieve the Permittee of any expense, loss, damage, or other liability which might be incurred as a result of damage to the POTW, natural resources, or any other damage to person or property; nor shall such notification relieve the Permittee of any fines, penalties, or other liability which may be imposed pursuant to the District’s Rules and Regulations. D. Accidental Discharge/Slug Discharge Control Plans 1. The Permittee shall provide protection from accidental discharge or slug loads of pollutants regulated under this permit and the District’s Rules and Regulations. The Permittee shall submit a Standard Operating Procedure (SOP) for addressing any spills during waste acceptance and disposal and submit to the District prior to acceptance of any waste. The Permittee shall keep this SOP up-to-date and submit any modification to the District. 2. Notice to employees. The Permittee shall train all employees, contractors or others that oversee discharge on proper practices. The Permittee shall keep documentation of this training (date, time, subject matter and employee (contractor) name. E. Pretreatment Facilities Requirement Pretreatment Facilities: If the District determines that additional pretreatment is necessary including flow equalization, the Permittee shall provide wastewater treatment as necessary to comply with this Permit and shall achieve compliance with all Pretreatment Standards and Requirements pursuant to Section 5.14 of the District’s Rules and Regulations. Additional Pretreatment Measures: Whenever deemed necessary, the District Manager may require the Permittee to restrict their discharge, relocate and/or consolidate points of discharge, 8 and such other conditions as may be necessary to protect the POTW and demonstrate the Permittee’s compliance with the requirements of this Permit. F. Permit Noncompliance The Permittee must comply with all conditions of this Permit. Any permit noncompliance constitutes a violation of the District’s Rules and Regulations. Such a violation may result in the immediate suspension and/or revocation of this Permit and an enforcement action, including the imposition of penalties as provided for in Section 5.20 of the District’s Rules and Regulations. If the Permittee is in Significant Noncompliance with applicable Pretreatment Standards and Requirements, the District Manager shall publish the Permittee and facts surrounding the SNC in the Grand Junction Daily Sentinel. G. Federal and/or State Laws Nothing in this permit shall be construed so to preclude the institution of any legal action or relieve the Permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable federal and/or state law or regulations. H. Records Management The Permittee shall retain, and make available for inspection and copying, all records of information obtained pursuant to any monitoring activities required by this Permit, any additional records of information obtained pursuant to monitoring activities undertaken by the Permittee independent of such requirements, and documentation associated with Best Management Practices. These records shall remain available for a period of three (3) years. This period shall be automatically extended for the duration of any litigation concerning the Permittee or the District, or where the Permittee has been specifically notified of a longer retention period by the District Manager. I. Duty to Provide Information The Permittee shall furnish to the Director or his duly authorized representative, within a reasonable time, any information which the Director or his duly authorized representative may request, to determine whether cause exists for modifying, revoking and reissuing, terminating this permit or to determine compliance with the permit. The Permittee shall also furnish, upon request, copies of records required to be kept by this permit. J. Right of Entry Whenever it shall be necessary for the purposes of this Permit and the District’s Rules and Regulations, the District Manager may at any time and without notice, take samples, observe the Permittee, review logs, inspect all facilities and equipment used by the Permittee, take photographs or copy any records kept by the Permittee related to the activities covered by this Permit. 9 K. Permit Modification and Revocation 1. Permit Modification: The District Manager may modify wastewater discharge permit as specified in Section 5.17 of the District’s Rules and Regulations. 2. Permit Revocation. The District Manager may revoke the wastewater discharge permit as specified in Section 5.18 of the District’s Rules and Regulations. L. Property Rights The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state or municipal laws and regulations. M. Severability The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstances, is held invalid, the application of such provisions to other circumstances and the remainder of the permit shall not be affected thereby. O. Confidentiality All records, reports, data or other information supplied by the Permittee as a result of any disclosure required by these Regulations or information and data from inspections shall be available for public inspection. These provisions shall not be applicable to any information designated as a trade secret by the person supplying such information. Materials designated as a trade secret may include but shall not be limited to processes, operations, style of work or apparatus or confidential commercial or statistical data. Any information and data submitted by the user which is desired to be considered a trade secret shall have the words, "Confidential Business Information," stamped on each page containing such information. The Permittee must demonstrate to the satisfaction of the District that the release of such information would divulge information, processes or methods of production entitled to protection as trade secrets of the Permittee. Information designated as a trade secret shall remain confidential and shall not be subject to public inspection. Such information shall be available only to officers, employees or authorized representatives of the District charged with enforcing the provisions of these Regulations and properly identified representatives of the U.S. Environmental Protection Agency and the Colorado Department of Public Health and Environment. Effluent data from any User whether obtained by self-monitoring, monitoring by the District or monitoring by any state or federal agency, shall not be considered a trade secret or otherwise confidential. All such effluent data shall be available for public inspection. NOTE: All layouts and renderings are conceptual representations only and subject to variances. // DOUBLE–ENDER WELLSITE UNIT SAMPLE UNIT SPECIFICATIONS Two separate suites each containing: • One private bedroom (single or double occupancy) • One three–piece bathroom • In–suite workstation • Satellite TV systems & hardware • Stacked laundry • Full kitchen • Personal temperature control in each room • Walls engineered to reduce noise transfer • Customizable to accommodate more sleeping space and less work space • Lockable storage SAMPLE UNIT DIMENSIONS • UNIT: 60'0" x 14'x0" 14'0" 60'0" civeo.comStay Well. Work Well.VER_211126