Waterbox Entry

[Fermi2]

Does your utility allow Waterbox entry w
When the plant is online?
We have a guy at my current utility who says it is against OSHA rules.
Both utilities I worked at allowed it

[GLW]

Yes, it's Permit Required with all and everything which Permit Required entails,...

Utilities do not get this wrong, they may choose not to exercise the full monty required to get it right while on-line and thus not perform water box entries while on-line, but they do not get it wrong when they do perform water box entries on-line,...

it's all in the context,...

I have been in water boxes while on-line,...

And since 1994 just in case the really astute are paying attention,...

[Fermi2]

Irrc the utility can downgrade it to Non Permit Required.
What you stated is exactly within my experience.
We isolated the water box which was an evolution in and of itself.
Then drained down. Open the holes did the confined space thing
Then let people go to work .

Right now it's strange here because the utility hasn't done any benchmarking on anything.
So because one PM believes it is illegal maintenance does not Jump boxes they hire a contractor to do it. Why this is ok is beyond me.

I have been involved in it since 1990.

If you don't mind could you list the utilities ?

[Ksheed]

Irrc the utility can downgrade it to Non Permit Required.
What you stated is exactly within my experience.
We isolated the water box which was an evolution in and of itself.
Then drained down. Open the holes did the confined space thing
Then let people go to work .

Right now it's strange here because the utility hasn't done any benchmarking on anything.
So because one PM believes it is illegal maintenance does not Jump boxes they hire a contractor to do it. Why this is ok is beyond me.

I have been involved in it since 1990.

If you don't mind could you list the utilities ?

PM sent.

[GLW]

It may be a context issue, to wit:

There may be an operating parameter which precludes effective isolation of the waterbox when on-line,...

In that or a similar scenario the competent person saying no to the entry is correct in laying it on an OSHA rule because effective isolation is one of the conditions required,...

The cooperative sharing of a tidbit of knowledge such as the one illustrated above will almost always make everybody who is not seeing the problem go "Ahhhhhh!, Okay, I get it.",...

The defining character of the problem being the "cooperative sharing" of said tribal knowledge,...

class over,...

check your PM's

[Fermi2]

Thanks guys. Great input. I was talking so ideal. Any Leakby handled via drains . Confined space parameters sat.
This guy who btw has zero OSHA experience just blurted out it is against OSHA regs because single isolation isn't allowed. I was like uh how do you do any maintenance at all.

He tried equating to isolating a high pressure feed water heater at power . Totally different animals .

[Fermi2]

GLW I received your Pm , I tried thanking you but your inbox is full.

[GLW]

GLW I received your Pm , I tried thanking you but your inbox is full.

I gotta pay up my GM dues,...

I'll get around to it,......eventually,.....

[Already Gone]

If the waterbox is isolated and properly tagged, what's the problem.
You probably can downgrade to non-permit required space once you install some scaffolding.  Prior to that, the configuration would preclude that, but it only takes a little time to put in some planks.

[Fermi2]

My point exactly. Our plant managers are not exactly the brightest crayolas in a pack of 2048

[retired nuke]

Single isolation will generally leave it a permit space.
Scaffolding will be needed.
Video / audio can be used by the attendant to monitor entrants - camera inside can be on a magnet mount. (applies to BWR / ALARA). Tell RP to share - the CS hazard outweighs the Rad hazard...
A permit space requires a rescue plan - lean toward trained team vs calling the local FD for retrieval..

[Fermi2]

No rad hazard here. I am the Generation Training Manager at a fossil utility now.
I am also the manager of generation safety.
I would love to use a local team but my utility elected to go with contractors.
Had they tried going internal the union would have demanded a pay raise for something they do once a year.
Here is the weird thing. Contractors use their own confined space program provided it has at least the requirements ours does. One contractor defines everything as permit required.
So you might see 15 guys in a tank non permit required and 5 permit required with a rescue team

[GLW]

No rad hazard here. I am the Generation Training Manager at a fossil utility now.
I am also the manager of generation safety.
I would love to use a local team but my utility elected to go with contractors.
Had they tried going internal the union would have demanded a pay raise for something they do once a year.
Here is the weird thing. Contractors use their own confined space program provided it has at least the requirements ours does. One contractor defines everything as permit required.
So you might see 15 guys in a tank non permit required and 5 permit required with a rescue team

As typed it appears your scenario includes permit required work taking place in the same confined space and at the same time that non-permit work is being conducted.

this presents a teachable moment:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21597

as you are the training guy, the above link is just a "soup starter" for your intimate introduction to the potentially harrowing world of confined space work,...

Already Gone is an expert,....

then again, he's a professional, and deserves a purchase order before applying his skills beyond the rudimentary "go here, read that" assistance,....

but, you're a smart guy too, and "go here, read that" is likely as much help as you would ever need to figure it all out yourself,....

so we're all really cool, smart guys just chewing the professional fat here,....

the fact we three are also former ELTs is just a priceless bonus for the viewing public,... 

[SloGlo]

the fact we three are also former ELTs is just a priceless bonus for the viewing public,...  

aye just new their was a problem....

[Chimera]

Okay, I'm a little puzzled.  Are you guys talking about entering the end bells (cooling side) of the condenser at power (which I've done as a permit required confined space) or actually entering the waterbox while at power?

[Fermi2]

You do realize end bells and Waterbox are the same thing right?

[Fermi2]

Thanks GLW. And how the heck did I post this in an instrument q and a section

[Bonds 25]

We here at Columbia have actually plugged tubes in one of our waterboxes at power (reduced of course)

I want to say it was a non permit required confined space during the plugging (although I'm not 100% positive)......and no these were not tubes from our brand spanking new condenser (that took 170 days to install)

[Already Gone]

You might want to keep the rescue team as a contingency.  It's pretty certain that they will be needed at least while the scaffolds are being built. 
Keep a good eye on temperature and humidity.  If you can control that with ventilation, I'd say that you could probably reclassify.  There is no way to be sure until you open the manway, but the residual heat from the tubesheet could last for days if you have been running that condenser.  Heat stress conditions might make you want to keep it permit required in that case.
If your plant has kept good records of prior entries, you might be able to make the call based on historical data, but don't rely simply on the fact that it was reclassified during previous entries.  Without hard data, you could just be repeating the same faulty assumption.  But, the fact is that you really never do know for sure until you open it.  My guess is that a fossil plant probably doesn't have a WBGT and hasn't ever taken (let alone recorded) readings.  This is where your nuke background is going to come in very handy.
Single isolation isn't a problem for a low-pressure/low-energy system.  If the valves aren't leaking, they aren't leaking.  If this were an ammonia tank or the steam side, I'd be all for a double block and bleed isolation.  Circ water is only a hazard if it all rushes in at once.  OSHA regs don't require anything other than an effective isolation procedure.

[Fermi2]

Thanks this guy bringing up OSHA was a new thing to me. I will have to see what the contractors do when they enter. I bet we have WBGT data or at the minimum BMW our primary contractor has it. For work they have done in the past they have performed extensive surveys for various items and since I am a nuke I believe in piracy.
So whenever someone has a question I usually say let's ask BMW safety and they provide.
Thanks again guys and if I ever see any of you I owe a few beers!

[Chimera]

You do realize end bells and Waterbox are the same thing right?

Thanks for the clarification.

[Fermi2]

It's ok thanks for participating.

[Ksheed]

It's been a while since we did it, but... At a PWR while on-line, no downpower, Ops isolated an entire pass. Drained it down, opened all manways, installed ventilation fans to force the residual heat out of the end bells and got it classified as non-permit confined space. Didn't require any scaffolding, unless you call one wood plank wedged in there for a seat scaffolding.