1. Manual Tank Gauging Hazard Alert:
Are We Implementing the Recommended Controls to Protect Employees?
Gulf Coast AIHA-ASSE Meeting – October 6, 2016
Presenter: Reggie Wills
© 2016 WM Intellectual Property Holdings, L.L.C.
Page 1

2. Objectives Help improve awareness –
This presentation is solely for educational purposes and provides only a general description of certain rules and regulatory requirements.  For a complete description, please consult the relevant laws, rules and requirements. Nothing in this presentation constitutes legal advice and you should not legally rely on any information  provided in this presentation. We make no warranty, express or implied, with respect to such information and disclaim all liability resulting from any use or reliance of this information.
THIS PRESENTATION MAY NOT BE DUPLICATED OR USED WITHOUT wASTE mANAGEMENT’S PRIOR WRITTEN CONSENT.
Help improve awareness –
Potential dangers of manual tank gauging and sampling at oil and gas extraction sites
As explained in the NIOSH-OSHA Hazard Alert – February 2016
Collaborate –
With oil and gas industry IH and safety practitioners
To mitigate the risks of injury and illness for workers involved in tank gauging and sampling
© 2016 WM Intellectual Property Holdings, L.L.C.

3. Waste Management Network
Introduction
Waste Management Network
© 2016 WM Intellectual Property Holdings, L.L.C.

4. Oil and Gas Industry Involvement
Introduction
Oil and Gas Industry Involvement
Wastes transportation and disposal
In-plant management of waste streams
Downstream
© 2016 WM Intellectual Property Holdings, L.L.C.

5. Oil and Gas Industry Involvement
Introduction
Oil and Gas Industry Involvement
Primarily wastes hauling
Midstream
© 2016 WM Intellectual Property Holdings, L.L.C.

6. Oil and Gas Industry Involvement
Introduction
Oil and Gas Industry Involvement
WM acquisitions
Reliable Environmental Transport – February 22, 2012
Summit Energy Services and Liquid Logistics – August 1, 2013
Concord Field Services, L.L.C. – November 1, 2013
Pad services; hauling (e.g., produced water, involves manual tank gauging); disposal; spill response; civil (construction)
S&H focus – Prevent fatalities, severe injuries/illnesses
Pad Services
Frack tank, mud pit, and rig cleaning
Hauling
MSW, drill cuttings, clean dirt, liquids
Disposal
Liquids, sludges, and solids
Spill Response
Spill cleanup activities
Civil (construction)
Perform construction activities such as installing haul roads to sites and/or installing tanks at the oil and gas well pads
Upstream
© 2016 WM Intellectual Property Holdings, L.L.C.

7. Manually Gauging the Level of Process Fluid
Fixed Production Oil Tank
1 - Worker looks into an open hatch
2 - In some regions, workers gauge oil tanks by opening tank hatches, visually observing liquid levels, and then manually measuring liquid oil levels
3 - A common design, fixed oil tanks are interconnected for both liquid and vapor, allowing contents to equalize over multiple tanks. Equalization of tanks can result in a high volume of off-gassed vapors when a tank hatch is opened
4 – Windsock, a visual indicator for the worker to stay positioned upwind
Photo: Todd Jordan, Occupational Safety and Health Administration
© 2016 WM Intellectual Property Holdings, L.L.C.

8. Manually Gauging the Level of Process Fluid
Fixed Production Tank
Photo: NIOSH
© 2016 WM Intellectual Property Holdings, L.L.C.

9. Manually Gauging the Level of Process Fluid
Fixed Production Tank
This graph shows that the count and rate of work-related fatalities in the oil and gas extraction industry are among the highest across all industry sectors.
For the oil and gas extraction industry in 2014, the U.S. Bureau of Labor Statistics reported 183 work-related fatalities at a rate of 14.2 fatalities per 100,000 full-time equivalent workers. This fatality rate is approximately 4 times higher than the all-worker fatality injury rate of 3.4 fatalities per 100,000 full-time equivalent workers.
WM Employee
WM Employee
© 2016 WM Intellectual Property Holdings, L.L.C.

10. Tracking Manual Tank Gauging/Sampling at WM
December 2014 – WM IH exposure assessment, North Dakota, well monitors/pumpers
Full-shift total hydrocarbon estimates: 5.8 – 140 mg/m3
Short-term total hydrocarbon estimates: 480 – 1,300 mg/m3
April 22, 2015 Wall Street Journal
9 oil workers have died since 2010, performing manual tank gauging or collecting samples of oil. 
Fatalities occurred in North Dakota, Colorado, Texas, Oklahoma, and Montana. 
Exposure to unusually high concentrations of hydrocarbons, including benzene, suspected cause.
Fatal work injuries in the private mining, quarrying, and oil and gas extraction industry increased 18 percent in 2014, and the fatal injury rate also increased to 14.2 per 100,000 FTE workers in 2014 from 12.4 per 100,000 FTE workers in Oil and gas extraction industries recorded 144 fatal injuries in 2014, a new high for that industry group.
© 2016 WM Intellectual Property Holdings, L.L.C.

11. Tracking Manual Tank Gauging/Sampling at WM
NIOSH science blog
Researchers identified 9 fatalities of oil and gas extraction workers from January 2010 to December associated with tank gauging or sampling.
The degree of detailed information about each case varies, all have in common manually gauging or sampling production tanks at oil and gas well sites.
Circa July 2015, Wall Street Journal
Headline - Widow Awarded Benefits in Tank Fumes Case
Story - In Colorado, Jim Freemyer, a 59-year old truck driver was found unconscious last July with his head hanging over the hatch of an oil tank. Mr. Freemyer’s job involved opening hatches atop tanks to take samples and measure levels inside.
Review these learning objectives.
Set an expectation of achieving these objectives by the end of this learning session.
© 2016 WM Intellectual Property Holdings, L.L.C.

12. Tracking Manual Tank Gauging/Sampling at WM
September 2015 – Phone Discussion with a NIOSH Researcher
Tank gauging involves 1930s technology specified in Bureau of Land Management regulations & API standards for measuring levels in tanks on federal leased land.
Technology to measure levels from the ground, in use in Eastern U.S. where most wells are on private lands.
There are potential cost concerns with retrofits.
Process water and crude tanks share a common headspace – there can be hydrocarbons from crude oil in the headspace of the process water tanks.
Headspace gas is directed to a flare, when the hatch is first opened, not uncommon for flare decrease extinguish.  Gas feeding the flare is released through the open hatch.
Light end hydrocarbons at these concentrations will not be captured by an OV respirator.
Review these learning objectives.
Set an expectation of achieving these objectives by the end of this learning session.
© 2016 WM Intellectual Property Holdings, L.L.C.

13. Tracking Manual Tank Gauging/Sampling at WM
November 2015 – WM Safety Services System Safety Advisory
Workers can be exposed to levels of butane, propane, pentane and other low molecular weight hydrocarbons in excess of IDLH thresholds near open production tank hatches.
WM IH exposure assessments from 2014 and 2015 indicate the potential for similar exposure scenarios for WM workers performing manual tank gauging.
Work with customers to develop alternative tank gauging procedures so workers do not have to routinely open hatches.
Due to potential for an IDLH atmosphere, require supplied air respirators for workers manually gauging or sampling production tanks and implement a buddy system.
Review these learning objectives.
Set an expectation of achieving these objectives by the end of this learning session.
© 2016 WM Intellectual Property Holdings, L.L.C.

14. Tracking Manual Tank Gauging/Sampling at WM
January 2016 – CDC Morbidity and Mortality Weekly Report
Exposure to high concentrations of hydrocarbon gases and vapors and oxygen-deficient atmospheres during manual tank gauging and sampling can pose a risk of sudden cardiac death.
Implement alternative fluid sample collection points, remote monitoring of fluid levels, use of gas monitors, and respiratory protection.
February 2016 – WM North Dakota operations team received an notification from the North Dakota Petroleum Council (NDPC) April WM received an notification from IH consultant NIOSH-OSHA Hazard Alert: Health and Safety Risks for Workers Involved in Manual Tank Gauging and Sampling at Oil and Gas Extraction Sites – February 2016
Review these learning objectives.
Set an expectation of achieving these objectives by the end of this learning session.
© 2016 WM Intellectual Property Holdings, L.L.C.

15. NIOSH-OSHA Hazard Alert – February 2016
Task
Opening tank hatches to manually gauge or collect fluid samples on production, flowback, or other tanks (e.g., drip pots) that contain process fluids.
© 2016 WM Intellectual Property Holdings, L.L.C.

16. NIOSH-OSHA Hazard Alert – February 2016
Hydrocarbon gases and vapors toxicity (gases - methane, ethane, propane, butane; vapors - pentane, hexane, benzene, and xylene)
Oxygen-deficient atmospheres
Fires and explosions
© 2016 WM Intellectual Property Holdings, L.L.C.

17. NIOSH-OSHA Hazard Alert – February 2016
Hydrocarbon gases and vapors toxicity (gases - methane, ethane, propane, butane; vapors - pentane, hexane, benzene, and xylene)
Oxygen-deficient atmospheres
Fires and explosions
© 2016 WM Intellectual Property Holdings, L.L.C.

18. NIOSH-OSHA Hazard Alert – February 2016
Worker Opening Hatch
Hatch Venting
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19. NIOSH-OSHA Hazard Alert – February 2016
Worker Leaning Over Hatch
Hatch Venting
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20. NIOSH-OSHA Hazard Alert – February 2016
Estimated Exposures – OSHA
Well sites in North Dakota, tank gauging activities, 2014
Full shift and short term PBZ and peak
IDLH concentrations (x 50) of hydrocarbon gases and vapors, including propane, pentane, methyl butane, hexane, 2-methyl pentane, and 3-methyl pentane, 1 foot above hatches
Total hydrocarbon gas and vapor concentrations of 179,000 ppm and 219,000 ppm in the plumes above two thief hatches, plus breakthrough
> 10% LEL and < 19.5% 02, production tanks, open thief hatches, during gauging and sampling
Benzene over exposures for STEL and 8-hr TWA
© 2016 WM Intellectual Property Holdings, L.L.C.

21. NIOSH-OSHA Hazard Alert – February 2016
Estimated Exposures – NIOSH
6 well sites in Colorado and Wyoming, flow back and production activities, 2013
Full shift and short term PBZ and peak
Benzene
15 of 17 > REL, 0.1 ppm
Some samples > NIOSH STEL, 1 ppm
All < OSHA PEL, 1ppm
Avg. for workers tank gauging 5X avg. for worker not tank gauging
Peak concentrations at open hatches > 200 ppm
Sustained atmospheres of 40% LEL adjacent to separators and flow back tanks
© 2016 WM Intellectual Property Holdings, L.L.C.

22. NIOSH-OSHA Hazard Alert – February 2016
Fatality Investigations
1 foot above the open thief hatch, O2 < 11%, LEL > 10%
Fatality case # 7
Three weeks prior to fatal event – worker was examined in an emergency room after experiencing altered consciousness while gauging a tank. Gas monitor data during this event revealed a 5-minute interval, concurrent with his symptoms, when O2 concentrations were in the range of 10% to 15% and LEL > 10%.
On the day of his death - gas monitor indicated LEL > 10%, O2 = 7%.
© 2016 WM Intellectual Property Holdings, L.L.C.

23. NIOSH-OSHA Hazard Alert – February 2016
Fatality Mechanism
Sudden exposure to high concentrations (>100,000 ppm) of low– molecular weight hydrocarbon gases and vapors, accompanied by displacement of air, resulting in O2 deficiency.
Inhaled O2 concentrations of <15% can significantly impair central nervous system function, and concentrations of <10% can result in loss of consciousness and possible death within seconds to minutes.
Low O2 blood levels (hypoxemia) can exacerbate cardiac ischemia (lack of blood flow and oxygen to the heart muscle) and increase the release of epinephrine (adrenalin).
© 2016 WM Intellectual Property Holdings, L.L.C.

24. NIOSH-OSHA Hazard Alert – February 2016
Fatality Mechanism
High concentrations (i.e., 50,000 ppm to ≥100,000 ppm) of low– molecular weight hydrocarbons, particularly butane, have been shown in animal studies and human reports to sensitize the heart to epinephrine-induced ventricular fibrillation, a lethal cardiac arrhythmia.
Simultaneous exposure to high levels of low–molecular weight hydrocarbon gases and vapors and a low O2 atmosphere above an open tank hatch poses a risk for sudden cardiac death.
© 2016 WM Intellectual Property Holdings, L.L.C.

25. NIOSH-OSHA Hazard Alert – February 2016
Worker Fatalities
Nine fatalities , six occurred in 2014, one in 2013, one in 2012, and one in 2010.
Three occurred in North Dakota, three in Colorado, one in Texas, one in Oklahoma, and one in Montana.
All fatalities occurred at crude oil (production) tanks.
Four fatalities occurred during tank gauging. Five additional fatalities occurred during sampling by pumpers/truckers.
© 2016 WM Intellectual Property Holdings, L.L.C.

26. NIOSH-OSHA Hazard Alert – February 2016
Worker Fatalities
In one case, the worker sought a medical evaluation for health effects (dizziness, disorientation, etc.) experienced during prior gauging activities.
The median age of workers was 51 years (range = 20–63 years), all were male.
All victims were working alone at the time of the incidents and were found collapsed on a tank or catwalk, or at the base of the catwalk stairs.
In at least five cases, the hatch was open when the worker was found.
© 2016 WM Intellectual Property Holdings, L.L.C.

27. NIOSH-OSHA Hazard Alert – February 2016
Recommended Controls (10 total)
Implement alternative tank gauging and sampling procedures that enable workers to monitor tank fluid levels and take samples without opening the tank hatch.
Retrofit existing tanks with dedicated sampling ports.
Install thief hatch pressure indicators – allows for actuating a blowdown valve or venting to a flare.
Do not permit employees to work alone.
Use supplied air respiratory protection.
© 2016 WM Intellectual Property Holdings, L.L.C.

28. Objectives Help improve awareness –
Potential dangers of manual tank gauging and sampling at oil and gas extraction sites
As explained in the NIOSH-OSHA Hazard Alert – February 2016
Collaborate –
With oil and gas industry IH and safety practitioners
To mitigate the risks of injury and illness for workers involved in tank gauging and sampling
© 2016 WM Intellectual Property Holdings, L.L.C.