1. Chicago Area Facilities (CAF) Ground Disturbance and Excavation Procedure

2. 2 Ground Disturbance and Excavation Procedure: Who, What & When Who does it apply to? −All individuals who work at CAF, including tenants (per lease agreement) −Does not pre-empt or eliminate the need for other applicable permits, procedures, policies or guides What is it? −A procedure establishing the minimum requirements to be followed when BP employees and contractor personnel are engaged in ground disturbance activities including entry into or work around excavations When does it have to be implemented? −Roll-Out Date: November 24, 2009 −Implementation deadline: December 30, 2009

3. 3 Roles and Responsibilities Designated Approver −Ensures that Ground Disturbance and Excavation Permit requirements are met-including onsite inspection-before issuing the permit −Acts as the independent authority as to whether work shall proceed Performing Authority (PA) −Obtains an approved Ground Disturbance and Excavation Permit, when required −Conducts a TSA before work begins −Closes the permit and returns it to IISN HSSE when work is complete

4. 4 Roles and Responsibilities Project Manager (PM) −Develops the work plan and ensures everyone involved has the opportunity to review it, including consulting technical experts and operations −Acts as the Task Risk Assessment (TRA) Team Leader; this cannot be delegated −Obtains and analyzes site drawings and arranges scan −Conducts a site visit with the PA, HSSE, BU Rep. and essential technical experts −Provides a plot plan of the ground disturbance area and ensures the field location is clearly marked showing the ground disturbance location, buried items, the need for hand digging, and scan data if applicable −Ensures communications with adjacent operations and the affected BU −Ensures that the work plan is followed and other arrangements are in place to mitigate the risks involved

5. 5 Roles and Responsibilities Personnel Performing the Work −Performs ground disturbance and excavation only when properly trained −Participates in a TSA prior to starting work, including review of the permit, inspections and related documents −Visually inspects all equipment for damage before use. Immediately removes from service all defective or damaged equipment until repaired and tested −Surveys the area to assure safe work conditions −Knows the location of and how to use the nearest telephone, fire alarm, emergency communication system, fire extinguisher, first aid kit, etc., before starting work −Takes immediate action–including work stoppage–to stop unsafe work practices, conditions, or non-compliance with this procedure’s requirements

6. 6 Roles and Responsibilities Excavation Competent Person −Qualified as a designated competent person in regards to excavations and related OSHA requirements (29 CFR 1926.650 -.652) −Performs daily inspections of the excavation work site and authorizes work −Determines if excavation is a confined space −Inspects excavation work site if conditions have changed −Maintains and signs the inspection log Business Units −Ensures they understand the potential ramifications of excavation when notified that these tasks will take place adjacent to or within their area

7. 7 Roles and Responsibilities IISN HSSE −Assures the overall implementation and compliance with this procedure; familiar with this procedure and utilizes expertise at their disposal to ensure employees are protected from excavation hazards −Identifies the designated Excavation Competent Person(s) for excavation activities on-site −Ensures that Excavation Competent Persons have been assigned to inspect the safety of excavations and monitor the work for any hazardous situations −Confirms each excavation job is properly evaluated and prepared, with hazards being addressed, ensuring employees are protected

8. 8 Roles and Responsibilities IISN HSSE −Maintains an active permit system that easily identifies all active ground disturbance and excavation on the site −Audits a representative sample of ongoing ground disturbance and excavation activity to ensure that it is being conducted in accordance with the permit −Files completed permits (including daily inspection forms) in a manner that makes the permit readily available for review −Maintains the list of Designated Approvers −Maintains a current copy of the BU contact list −Maintains the Ground Disturbance and Excavation Qualification Package

9. 9 General Permit Requirements −A permit is required for all ground disturbances that exceed 12 inches, before work begins. Examples of ground disturbance include, but are not limited to: excavating, digging, trenching, plowing, drilling, tunnelling, auguring, blasting, probing, scraping and grading −Daily Excavation Inspection forms may be used to reaffirm permits for more than one shift

10. 10 Permit Exceptions −Using fill dirt as an alternative to grading low spots or areas where erosion has occurred, or using stockpiled material, does not constitute a ground disturbance activity −Grounds-keeping activities where mechanical equipment is not used for excavation and the manual penetration does not exceed 12 inches in depth

11. 11 Identify the Need for Work −The Project Manager and Performing Authority define the scope of the work, including the location and size of the opening −Assemble site drawings to determine the location of underground utilities and structures

12. 12 Plan and Risk Assess the Work: Scanning −The Project Manager and Performing Authority consult with site technical experts and operations −Technical experts determine the level of ground scanning required −Cantera and outside Naperville fence line contact JULIE −The Project Manager and/or Performing Authority mark area for scanning in the field −The Project Manager reviews the record drawings with the scanning company, and risk assess the area to determine the impact of SIMOPS −Scanning company performs the scan

13. 13 Plan and Risk Assess the Work: Scanning Scan indicates the proposed site is acceptable −The Scanning Contractor marks all utilities or structures identified by the scan on the ground, and photographs, and submits a written report to the Project Manager Scan indicates the proposed site is NOT acceptable −The Project Manager and Performing Authority consult with site technical experts and Operations

14. 14 Plan and Risk Assess the Work −Assume Type C soil and evaluate shoring conditions −Prepare work plan and finalize the TRA, including the need to obtain other permits

15. 15 Authorizing the Work −Assemble a team of technical experts, HSSE, Project Manager, Performing Authority and the BU Representative to review the work plan and conduct a site visit (if necessary) −Appropriate disciplines and the PA sign off on the permit −Permit submitted to the Designated Approver for their signature −The Designated Approver signs off on the permit −The permit is subject to further review and modification by the PM if the appropriate disciplines, PA, or Designated Approver do not sign off on the permit

16. 16 Work Proceeds: Conduct a TSA −The Performing Authority shall conduct a TSA with all involved workers and affected personnel prior to each job TSA topics include: −The Work Plan −Ground Disturbance and Excavation Permit −Applicable procedures −Required PPE −Additional permitting requirements −SIMOPS and other potential hazards

17. 17 Work Proceeds: Daily Permit Affirmation −The Excavation Competent Person reaffirms the permit for each shift using the Excavation Inspection Form after reviewing changes in site conditions and changes in personnel

18. 18 Closing the Permit −The PA closes the permit and returns it to IISN for recordkeeping −The PM ensures that drawings and associated reports, including scanning reports, are included in the project file for retention

19. 19 Cancelling/Suspending the Permit −Any alarm affecting the area of ground disturbance or excavation (evacuation, fire, etc.) shall suspend the permit until risks have been reassessed and the TSA revisited, as necessary −IISN or BP can suspend or cancel the permit given sufficient cause

20. 20 Training and Assurance Designated Approver Training −Complete the Designated Approvers Qualification Package Contractor/Sub-contractor −Documentation of contractor/sub-contractor scanning operations training shall be provided upon request to the Performing Authority −Employees involved in excavations shall be properly trained in accordance with this procedure Assurance −IISN shall audit completed permits and conduct periodic field audits of ongoing work to ensure compliance with this procedure

21. 21 Suggested Implementation Strategy Questions? −Contact Dan Zbinden, Procedure Custodian, 630-961-7677