S02 - PRESOL Attachment 03 - Steam System Report AE 672-25-107 - 120 pages_Part 1.pdf

DEPARTMENT OF VETERANS AFFAIRS

NETWORK CONTRACTING OFFICE 8

SAN JUAN VA HEALTH CARE SYSTEM

10 C. CASIA

SAN JUAN, PUERTO RICO 00921

A&E STUDY

REPLACE CAST IRON FITTINGS AND VALVES STEAM

DISTRIBUTION SYSTEMS VISN 8 – San Juan VAMC

CONTRACT NO. 36C24823C0107

Prepared for:

San Juan VAMC Final Submission

June 14, 2024

Prepared By:

David Keith, PE, CxA

President

01/23/2025

TABLE OF CONTENTS

EXECUTIVE SUMMARY

BACKGROUND

SCOPE OF PROJECT

MEANS AND METHODS OF DATA COLLECTION & PROJECT WORKFLOW

FACILITY OVERVIEW

OBSERVATIONS

RECOMMENDATIONS

BOILER START UP PROCEDURE REVIEW & RECOMMENDATIONS

APPENDICES

A. LICENSES & CREDENTIALS of KSM & ACUREN STAFF INVOLVED IN

REPORT DEVELOPMENT

B. OSHA INVESTIGATION 1502795 DATED MAY 12, 2021

C. BOILER START UP PROCEDURE FROM WEST PALM

D. EXAMPLE OF NEAR COMPLETE PROCEDURE FROM MIAMI

E. OSHA STANDARD PROCEDURE CHECKLIST

F. DESIGN ALERT 151

G. METALLURGIST REPORT

H. EXAMPLES OF MATERIAL, FITTING TYPES, AND CONNECTION TYPES

I. ASBESTOS SURVEY REPORTS

J. AS-BUILT REDLINED DRAWINGS

K. EDITED STEAM SPECIFICATIONS

L. STEAM DETAILS

EXECUTIVE SUMMARY

KSM A&E Federal Group, referred to herein as KSM, was contracted to conduct a full campus-wide steam distribution survey within all VISN 8 facilities to identify the locations of all cast iron, ductile, or malleable fittings, valve housings, piping, and components in the high pressure, medium, & low pressure (15psig and greater) steam distribution systems, and to inspect, document, and develop red-lined pdfs of the current systems. This survey is limited to above ground piping for steam systems and hot water distribution systems at a temperature of greater than 257 degrees Fahrenheit.

KSM and the VA agreed that testing every point across every station was not a feasible approach and could not be completed within budget or within the original period of performance time frame this project was given, due to a litany of logistical issues and the shear cost of the testing services. To mitigate the issues, the AE proposed testing a sample of fittings to be selected at random following the existing conditions survey, and then providing a statistical analysis to determine the distribution of cast iron fittings, or fittings constructed of malleable or ductile materials such as copper alloy.

In order to achieve a good representation of the entire steam distribution systems, the test point locations ranged from main steam headers, steam distribution piping runs, small medium pressure condensate return piping, pressure reducing valves, and steam traps. KSM also avoided testing multiple points on the same piping in the same areas, based on the assumption that piping of the same service, in the same area, was installed at the same time and of the same material. Visual inspections of these areas played a factor in sampling as well. If a certain area appeared to have been partially renovated, more test points were added to achieve an accurate sampling of the piping in that area.

Results were then summarized to show the distribution of materials. Results are written to be consistent with the published TIL specifications prior to any updates following the December 2021 design alert.

In addition to the testing, the contract also requires the A&E to edit the steam specifications for VISN8 and update per the design alert, perform an audit to the published boiler procedures, and develop a budget for future projects resulting from this study.

VA VISN 8 Summary

Location (In Order of

Precedence)

Total Number of

Components (A)

% of Positive Test (B)

% of Fittings non-butt weld (C)

Approx.

Number of

Components Requiring

Replacement (D)

Weighted Average to Establish

Precedence 100*(B*C*D

)/A Project Probable

Cost (Base)

Miami 1353 74% 95% 988 51.34 7,486,150

West Palm Beach 377 57% 91% 282 38.80

2,380,322

Orlando (Lake Baldwin) 375 66% 72% 287 36.37

3,161,356

San Juan 570 44% 56% 421 18.20 $

3,770,555

Tampa (JAH) 466 35% 58% 360 15.68 3,956,850

Bay Pines 598 33% 50% 417 11.51 3,598,988

Gainesville (Malcom Randall) 794 33% 42% 477 8.33

3,639,529

Lake City 982 23% 48% 723 8.13 7,551,872

Orlando (Lake Nona) 903 21% 44% 688 7.04

7,628,661

Total 43,174,283

BACKGROUND and CAUSE FOR STUDY

November 13, 2020, an explosion of the steam system occurred at West Haven VAMC in West Haven, Connecticut killing 2 and injuring 5 people.

Following the incident, an investigation was launched to determine the cause. Reference attached OSHA investigation 1502795 dated May 12, 2021. The report noted the following violations that resulted in catastrophic failure which led to injuries or death of VA maintenance personnel and contractors.

1. 29 CFR 1910.147(d)(2), Serious violation: Not utilizing orderly shutdown procedures.

2. 29 CFR 1910.147(d)(5)(i), Serious violation: All Potentially hazardous stored or residual energy was not relieved, disconnected, restrained, or otherwise rendered safe after the application of lockout or tagout devices to energy isolating devices.

3. 29 CFR 1910.147(f)(2)(i), Serious violation: When outside servicing personnel were engaged in activities in a facility, the onsite employer and the outside employer did not inform each other of their respective lockout or tagout procedures.

4. 29 CFR 1960.8(a), Serious violation: The head of each agency did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm, in that employees were exposed to struck-by and burn hazards associated with high-pressure steam water hammer events.

5. 29 CFR 1960.55(a), Serious violation: The agency did not provide safety and health training for supervisory employees.

6. 29 CFR 1910.147(c)(4)(i), Willful-Serious violation: Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section.

7. 29 CFR 1910.147(c)(4)(ii), Willful-Serious violation: Procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, 29 CFR 1910.147(c)(4)(ii)(A), (B), (C), & (D).

8. 29 CFR 1910.147(c)(6)(i), Repeat-Serious violation: The employer did not conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirement of this standard were being followed.

9. 29 CFR 1910.147(c)(7)(i), Repeat-Serious violation: The employer did not provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy control are acquired by employees.

10. 29 CFR 1910.147(f)(3)(ii)(D), Repeat-Serious violation: Each authorized employee did not affix a personal lockout or tagout device to the group lockout device before working on the machine or equipment.

As a result of the investigation, the VA issued design alert 003C2B-DA-151 on December 15, 2021:

Cast Iron Fittings/Valve Housings, Prohibition of Use in High and Medium Pressure Steam Distribution Systems

ISSUE: The VA has generally prohibited the use of Cast Iron fittings and pipe components (valves, steam traps, etc.) due to the risk of failure with shock loading. A recent accident involving the loss of human life has heightened the concern with the use of cast iron material on steam systems.

DISCUSSION: Based on the brittle nature of cast iron and the accident at a VA Medical Center, VA and VHA leadership has made the decision to discontinue the use of any cast iron or malleable fittings and components in high and medium pressure steam systems, whether existing or new. Facilities shall always use due diligence to avoid any sudden shocks to the steam distribution system, such as a water hammer or energizing a cold steam system without a proper warm-up sequence.

REQUIREMENTS: New Construction, NRM, or any repair or replacement project must not use cast iron fittings and components or malleable fittings anywhere in the high-pressure and medium pressure steam system (15psi or above). All new construction must use cast steel or forged steel fittings only.

This study and the subsequent report will address the identified issues through statistical analysis of each site to determine the overall risk of encountering cast iron, provide recommendations for remedial actions, audit the published standard operating procedures in comparison to the regulations noted in the OSHA report above, and other practices associated with the high and medium pressure steam systems.

SCOPE OF PROJECT

Where insulation is required to be removed, the contractor shall coordinate with the VA Facilities' Engineering staff and obtain approval for removal. The inspection team shall retain a specialized subcontractor to reinsulate all portions that may be removed by the inspection to validate the type of material.

The contractor shall review start-up procedures at each facility and make recommendations for changes to the procedures to mitigate the risk of deleterious effects of water hammer and shock loading on the piping system. The contractor shall provide a full written start-up procedure based on discussions with local staff, a review of existing standard operating procedures, and recommendations from the contractor subject matter experts.

The contractor shall provide all parts, services, labor, supervision, and specialty services to conduct a full campus-wide steam distribution survey within all VISN 8 sites as described below in “Locations” to identify the locations of all cast iron, ductile, or malleable fittings, valve housings, piping, and components in high pressure and medium pressure steam systems. This requirement covers systems operating at a pressure of 15 Pounds per Square Inch Gauge (PSIG) or greater and hot water distribution systems at a temperature of greater than 257 degrees Fahrenheit. This requirement only covers above-ground piping.

The contractor shall first trace out existing steam lines at each facility. The contractor shall inventory all existing cast iron, ductile, or malleable fittings, valve housings, piping, and components in high-pressure and medium-pressure steam systems and distribution systems for hot water or other liquids at a temperature greater than 257 degrees Fahrenheit. The contractor shall identify the fitting or component type, material, location, and type of distribution system (medium, high pressure, hot water/liquid). The contractor shall physically verify all locations and not rely on as-built drawings. If a facility has current as-built steam distribution drawings, the contractor shall mark on the as-built drawings, the location of each fitting as well as provide a table format of information. If the facility does not currently have as-built steam distribution drawings, the contractor shall utilize architectural floorplans to identify approximate locations as well as provide a table format of the required information.

The contractor shall also identify asbestos-containing materials (ACM) during this initial assessment. The contractor shall provide an Asbestos Abatement Plan based on the findings.

The Abatement Plan must comply with all VA requirements related to Environmental Control, Infection Control, Life Safety, Waste Management, and other Master Specification General Conditions (Division 01) found in VA’s Technical Information Library (TIL) at the following link:

https://www.cfm.va.gov/til/

The contractor shall retain an experienced metallurgist to help identify if a piping element or component is either steel or cast iron. The metallurgist shall apply only nondestructive testing (NDT) methods where applicable. A segment resulting to be inconclusive by either visual inspection or NDT shall be replaced in its entirety as deemed appropriate to ensure there is no cast iron material left. The contractor shall also develop and complete a risk assessment and interim safety measures specific to each facility. This should consider the condition of the fittings and systems, use, and the risk of failure of fittings, and should identify those areas most at risk so that the facility can prioritize replacement.

All work shall be documented in a final technical report to be submitted electronically to the VA Contracting Officer’s Representative (COR). The contractor shall provide a cost estimate for full replacement of all identified non-compliant fittings and piping. The estimate shall be broken down at the building level and shall also provide an estimate for full campus replacement.

The contractor shall perform all inspections without disrupting, removing, or demolishing any VA property. Any removal required to carry out the inspection shall be replaced at no additional cost to the Government and must be timely coordinated (at least 14 calendar days in advance) and be approved by the Government’s authorized representative.

MEANS AND METHODS OF DATA COLLECTION & PROJECT WORKFLOW

Phase 1 – Field Verification

• KSM utilized VA provided documents, as well as our library to organize all as-built drawings for each facility.

• Once collected, we conducted site visits with multiple teams to field verify the as-built documents.

• We conducted bulk sampling in order to determine if any test locations contained ACM within the insulation.

• Updated the as-builts drawings with red-lined pdfs. which will become the base files for the remainder of the project.

Following the field verification, we conducted a virtual meeting with the VA and project COR to go over the locations we identified for testing. The goal of this meeting was for all parties to be in agreement with test points and locations.

Phase 2 – Inspection & Test

• Removal of insulation to expose fittings.

• Metallurgical inspection and/or test to positively identify material.

• Reinsulating piping and fittings

Phase 3 – Report and Recommendation

Phase 3 consisted of gathering all of the information by this point in the project, and organizing it into a report, which will summarize the findings for each facility, as well as indicate the risk level noted for each area. This phase includes a schematic construction cost analysis for each facility based on the findings.

SAN JUAN VAMC FACILITY OVERVIEW

San Juan VAMC is located in San Juan, PR. The facility was originally built in 1966 and has expanded its capacity over the preceding years with the addition of the CLC in 1986, a South tower in 2006 and an administration building in 2009. Over San Juan’s history some of the steam system has been replaced, abandoned, expanded upon, or are still existing and in use.

Due to Puerto Rico’s tropical climate and proximity to the ocean, issues can arise with iron or steel components installed in un-conditioned areas, exterior areas, or in crawl spaces, as they are highly likely to rust or otherwise be damaged due to normal weather conditions. This can lead to potential hazards in the system.

VA SAN JUAN OBSERVATIONS

Concluding the metallurgical testing and the A&E visual inspections, the test results show that approximately 80% of threaded connections, 75% of bolted connections, and 80% of all fittings of nominal pipe diameter of 2” or less valves are constructed of cast iron, malleable, or ductile materials. These correlations lead to the conclusion that the majority of steam traps, valves, and fittings under 2” are constructed of cast iron, malleable, or ductile materials. The results are summarized and compared using several methods in order to draw conclusions from the samples. All butt-welded connections were found to be constructed of either wrought iron, forged iron, or cast steel, which is permitted. Appendix F will include pictures for how to identify materials based on markings or physical appearance.

The test results conclusively indicate that the majority of fittings, valves, and components with threaded, flanged, or bolted, and pipe size less than 2.5” nominal pipe diameter are likely to be cast iron, malleable or ductile materials.

The metallurgy test results also conclusively demonstrated that there was some correlation between age of the facility and use of cast iron, malleable, or ductile materials. As the steam piping specification has been updated to prohibit cast iron, and other malleable fittings in the steam distribution systems, there are still projects currently in construction that may have cast iron allowed in the specifications. As such, the results summarized above apply universally to all buildings on campus.

The following tables summarize all test points and identifies building number, floor, system, and description of what was tested. Please note that the metallurgical specialist report included as an appendix to this report only marks yes to items that are cast iron based or no to items that are copper, bronze, or other malleable or ductile materials. The test results include cast steel in the positive test results, and do not include any copper alloys as positive test results. As such, the A&E summarized results in the following tables, and the statistical analysis numbers vary slightly from the metallurgical numbers. The highlighted rows in the table indicate a positive result to cast iron or malleable/ductile fittings present in the test. Through tedious data analysis and statistical analysis, KSM was able to produce results that could be applied to all of the buildings and steam distribution piping at the San Juan VA Facility.

Test Point Distribution & Results Test

Point

Building Floor System Part Connection

Type Siz e

Material yes/ no

ACM

insulation?

1 E-1Q Boiler Room, GROUND

STEAM Valve Bolted 6

CAST

IRON

Yes

2 E-1Q Boiler Room, GROUND

STEAM Tee Bolted 8 STEEL NO

3 E-1Q Boiler Room, GROUND

STEAM Tee Butt Welded 6 STEEL NO

REPEAT

TEST POINT

REPEAT

TEST

POINT

REPEAT

TEST

POINT

REPEAT

TEST

POINT

REPEAT

TEST POINT

REPEAT

TEST

POINT

REP

EAT

TES

T

POI

NT

REPEAT

TEST POINT

5 E-1Q Boiler Room, GROUND

STEAM Valve Threaded

1/2

CAST

IRON

YES

6 LAUNDRY

LAUNDR

Y, GROUND

STEAM Elbow Butt Welded 4 STEEL NO

7 LAUNDRY

LAUNDR

Y, GROUND

STEAM Elbow Butt Welded 4 STEEL NO

8 LAUNDRY

LAUNDR

Y, BASEME

NT

STEAM Elbow Threaded 2

CAST

IRON

YES

9 LAUNDRY LAUNDR STEAM Other Threaded 2 CAST YES

Y, BASEME

NT

IRON

10 LAUNDRY

LAUNDR

Y, BASEME

NT

STEAM Elbow Threaded 2

CAST

IRON

YES

SOUTH

TOWER

JPH-3,

Mechani cal Room

STEAM

SUPPLY

Elbow Butt Welded 6 STEEL NO

SOUTH

TOWER

JPH-3,

Mechani cal Room

STEAM Elbow Threaded 2 STEEL NO

SOUTH

TOWER

JPH-3,

Mechani cal Room

MPS PRV Threaded 2

CAST

IRON

YES

14 BASEMENT

BASEME

NT,

THERAPY

POOL

STEAM Tee Threaded 2

CAST

IRON

YES

15 BASEMENT

BASEME

NT,

THERAPY

POOL

STEAM Elbow Threaded 1

CAST

IRON

YES

16 BASEMENT

BASEME

NT,

THERAPY

POOL

STEAM Valve Threaded 1

CAST

IRON

YES

17 BASEMENT

BASEME

NT, K13

STEAM Valve Bolted 3

CAST

IRON

YES

18 BASEMENT

BASEME

NT, L12

(L SIDE)

STEAM Valve Threaded 1

CAST

IRON

YES

19 BASEMENT

BASEME

NT, L12

(M SIDE)

STEAM Valve Threaded 1

CAST

IRON

YES

20 BASEMENT

BASEME

NT, P7

STEAM Valve Threaded 2 STEEL NO

21 e-1Q

BOILER

ROOM,

GROUND

STEAM Valve Bolted 6

CAST

IRON

YES

22 E-1Q

BOILER

ROOM,

GROUND

STEAM Elbow Butt Welded 6 STEEL NO

23 E-1Q

BOILER

ROOM,

GROUND

STEAM Elbow Butt Welded 6 STEEL NO

24 LAUNDRY LAUNDR STEAM Elbow Threaded 1 CAST YES

Y ROOM,

GROUND

IRON

25 LAUNDRY

LAUNDR

Y ROOM,

GROUND

STEAM Elbow Butt Welded 4 STEEL NO

LAUNDRY

BASEMENT

LAUNDR

Y, BASEME

NT

STEAM Elbow Butt Welded 6 STEEL NO

27 BASEMENT

BASEME

NT, J-16

STEAM Tee Butt Welded 6 STEEL NO

28 BASEMENT

BASEME

NT, H-16

STEAM Elbow Threaded 1.5

CAST

IRON

YES

29 BASEMENT

BASEME

NT, H-14

STEAM Elbow Butt Welded 4 STEEL NO

30 BASEMENT

BASEME

NT, H-14

STEAM Elbow Butt Welded 6 STEEL NO

31 BASEMENT

BASEME

NT, G-13

STEAM Elbow Butt Welded 4 STEEL NO

32 BASEMENT

BASEME

NT, J-12

STEAM Elbow Butt Welded 4 STEEL NO

33 BASEMENT

BASEME

NT, H-18

STEAM Elbow Butt Welded 6 STEEL NO

34 BASEMENT

BASEME

NT, K-18

STEAM Elbow Butt Welded 6 STEEL NO

35 BASEMENT

BASEME

NT, L-19

STEAM Elbow Butt Welded 6 STEEL NO

36 BASEMENT

BASEME

NT, M-11

STEAM Tee Threaded 1.5 Brass tee, VT only

YES

37 BASEMENT

BASEME

NT, L-6

STEAM Elbow Threaded 0.7

CAST

IRON

YES

38 BASEMENT

BASEME

NT, R-19

STEAM Elbow Threaded 1 STEEL NO

39 BASEMENT

BASEME

NT, E-5

STEAM Elbow Butt Welded 4 STEEL NO

40 BASEMENT

BASEME

NT, E-5

STEAM Elbow Butt Welded 4 STEEL NO

41 BASEMENT

BASEME

NT, A-23

STEAM Elbow Threaded 0.7

COPPER YES

42 BASEMENT

BASEME

NT, P-4

STEAM Elbow Butt Welded 4 STEEL NO

43 BASEMENT

BASEME

NT, S-23

STEAM Elbow Threaded 1.5

CAST

IRON

YES

44 BASEMENT

BASEME

NT, G-16

STEAM Valve Threaded 0.7

STEEL NO

The following information was collected from all 9 sites included with the study, and the results were summarized & compared to each other to calculate a statistical mean and standard deviation for the overall distribution of cast iron fittings through the site, and then used to calculate the probable replacement cost for each building and site. The row highlighted in green is the total number of fittings selected at random that were both a non-butt weld connection and was identified as cast iron or other malleable or ductile material.

Bay Pines James Haley Lake Baldwin Malcom Randall Lake City Lake Nona WPB Miami San Juan Total

598 466 375 794 982 903 377 1353 570 6418

51 55 29 49 44 48 23 43 43 385

9% 12% 8% 6% 4% 5% 6% 3% 8% 6%

17 19 19 16 10 10 13 32 19 155

33% 35% 66% 33% 23% 21% 57% 74% 44% 40%

Elbow/Tee 469 371 295 623 784 704 312 1191 502 5251

Valve/PRV 70 60 57 33 178 163 52 124 56 793

Steam Trap 22 25 23 8 20 36 13 38 12 197

Fitting Type

% of Total Population Sampled

Number of Samples

Number of CI/M/D Positive Test

% of Sample Population Positive

Overall Summary by Location Sample Location

Total Population Size

Bay Pines James Haley Lake Baldwin Malcom Randall Lake City Lake Nona WPB Miami San Juan Total

20 20 18 21 16 15 21 37 20 188

38% 36% 62% 43% 36% 31% 91% 86% 47% 49%

14 13 16 15 6 6 13 29 16 128

70% 65% 89% 71% 38% 40% 62% 78% 80% 68%

32 35 11 28 28 33 2 6 23 198

62% 64% 38% 57% 64% 69% 9% 14% 53% 51%

2 8 3 0 4 4 0 3 3 27

6% 23% 27% 0% 14% 12% 0% 50% 13% 14%

Test Summary by Fitting Size Relationship

% 2.5" and Larger CI/M/D

Total of 2.5" and Larger in Sample

% of Sample 2.5" and Larger

2.5" and Larger Sample Positive CI/M/D

2" and Below Sample Positive CI/M/D

% of Fittings 2" and Below CI/M/D

% of Sample 2" and Below

Total of 2" and Below in Sample

Sample Location

Bay Pines James Haley Lake Baldwin Malcom Randall Lake City Lake Nona WPB Miami San Juan Total

Elbow/Tee 40 39 18 42 39 38 18 27 32 293

Valve/PRV 10 14 2 8 4 8 4 12 10 72

Steam Trap 1 1 9 0 0 2 1 4 1 19

Elbow/Tee 10 11 8 14 6 6 15 20 12 102

Valve/PRV 6 9 2 1 3 3 4 8 8 44

Steam Trap 1 1 9 0 0 2 1 4 1 19

Elbow/Tee 25% 28% 44% 33% 15% 16% 83% 74% 38% 35%

Valve/PRV 60% 64% 100% 13% 75% 38% 100% 67% 80% 61%

Steam Trap 100% 100% 100% NA NA 100% 100% 100% 100% 100%

% of Sample Test Positive

Test Summary By Fitting Type Relationship

Fitting Type

Number of Positive Test

Sample Location

Bay Pines James Haley Lake Baldwin Malcom Randall Lake City Lake Nona WPB Miami San Juan Total

Total Tested 26 23 8 28 23 27 2 2 19 19

CI/M/D # 0 1 0 2 1 1 0 0 0 0

CI/M/D % 0% 4% 0% 7% 4% 4% 0% 0% 0% 0

Total Tested 26 32 21 20 21 21 21 41 24 24

CI/M/D # 16 20 19 13 9 9 11 32 19 19

CI/M/D % 62% 63% 90% 65% 43% 43% 52% 78% 79% 79%

31% 36% 66% 27% 20% 19% 48% 74% 44% 44%

Sample Location

Butt-Welded

Test Summary by Connection Type Relationship

Other Than Butt-Welded

CI/M/D % Number of Non-Butt welded fittings tested relative to total number of test subjects

Mean, standard deviation, and the 95% CI are calculated by taking results from all samples, omitting the upper and lower outliers to find average and standard deviation, then multiplying the standard deviation by 2, and adding to the mean. This method was developed using the methods contained within the textbook – “Applied Statistics and Probability for Engineers, 4th Ed.”

• Statistical Mean (µ) – 39%

• Standard Deviation (σ) – 15%

• 95% CI (µ+2* σ) – 69%

From the data collected we can conclude with 95% confidence that the recommendations stated below will be adequate to rid San Juan’s facility of all cast iron components in the steam system.

RECOMMENDATIONS

Based on the visual inspections, metallurgical test results, and statistical analysis, KSM recommends the replacement of all PRVs, valves, steam traps, all fittings with other than Butt- Welded connection types, and all other items of 2” or smaller overall pipe diameter that do not visibly show a stamp or marking that denotes it is constructed of cast steel, wrought or forged iron. In addition to the previous, KSM also recommends replacement of all butt welded fittings with markings or surface pitting associated with cast materials.

Due to the irregularities in insulation thickness, it is near impossible to say with 100% certainty that a fitting is threaded or not without removing insulation first. So, any future contract should include in the base bid the removal of all insulation and re-insulating all fittings regardless of if replaced.

New steam distribution piping shall be of approved material for the application. Refer to the specifications in the appendices of this report for replacement materials recommendations.

Scope of work line items should be:

1. Contractor shall identify all PRVs, valves, steam traps, and fitting type by connection.

i.e. threaded, butt-welded, or slip-on welded (flanged), or butt-welded.

a. All PRVs that do not contain a stamped ID tag with WCB engraved within shall be replaced with approved materials in accordance with design alert 151 and included specifications.

i. Isolate PRV using OSHA approved standard shut down and isolation procedures.

ii. Empty lines of any stored energy or condensation.

iii. Very lines are safe to work in.

iv. Any cutting shall be done in a manner that minimizes the amount of piping to replace.

b. All valves that do not contain a stamped ID tag with WCB engraved within shall be replaced with approved materials in accordance with design alert 151 and included specifications.

v. Isolate valves using OSHA approved standard shut down and isolation procedures.

vi. Empty lines of any stored energy or condensation.

vii. Very lines are safe to work in.

viii. Any cutting shall be done in a manner that minimizes the amount of piping to replace.

c. All steam traps that do not contain a stamped ID tag with WCB engraved within shall be replaced with approved materials in accordance with design alert 151 and included specifications.

ix. Isolate valves using OSHA approved standard shut down and isolation procedures.

x. Empty lines of any stored energy or condensation.

xi. Very lines are safe to work in.

xii. Any cutting shall be done in a manner that minimizes the amount of piping to replace.

d. All threaded and slip-on welded fittings 2” and smaller that do not contain a stamped ID tag with WCB engraved within shall be replaced with approved materials in accordance with design alert 151 and included specifications.

xiii. Isolate fitting(s) using OSHA approved standard shut down and isolation procedures.

xiv. Empty lines of any stored energy or condensation.

xv. Very lines are safe to work in.

xvi. Any cutting shall be done in a manner that minimizes the amount of piping to replace.

e. All butt-welded fittings with surface pitting or engraved stamps shall be replaced with approved materials in accordance with design alert 151 and included specifications. See appendices for example.

2. Contractor shall re-insulate all fittings with like materials and insulation thickness as adjacent or adjoining piping.

3. Mark all new insulation with system type, pressure, temperature, etc. in accordance with station standards.

4. Attend weekly virtual construction meetings, as well as monthly site walks with reports for each visit.

5. Following construction, provide all updated As-Builts in AutoCAD 2014 format as well as PDFs.

COST ESTIMATE

Replacement of all valves, PRVs, & steam traps, and replacement of all threaded, bolted, & slip-on welded or flange welded fitting in entire HPS & MPS systems with pressures of 15PSIG or greater, or hot water in excess of 257 degrees F.

Replacement cost include the following for each fitting type:

o Removal of insulation, o removal of fitting by cutting at least one side, o adding minimum of 3 linear inches of pipe,

▪ 3” nominal pipe diameter was used for calculation of cost, o welding at least one side of the fitting, and o insulation.

All associated material and labor are accounted for in the following cost model.

The table below identifies the probable cost to replace the recommended fittings, valves, etc.

per building, as well as the total for the San Juan VA Facility. For the approximate number of fittings to replace, other than valves and traps, KSM took the data from all sites to determine a statistical mean and standard deviation based on overall connection type, and added 2 standard deviations for a 95% confidence interval to determine an overall percentage of the total number of fittings, other than valves and traps, on site that will require replacement. Replacement cost for 100% of all valves, PRVs, and steam traps are included in the pricing detailed below. OH&P were calculated at 164% based on real cost associated with replacing fittings and insulation for the fittings, for the valves, PRVs, and steam traps, no real data was available, so RSMeans data was utilized to determine material cost and labor associated with replacement.

Building Fitting Type

Approx. Total

Number of

Fittings

Bulk

Sampling

Cost per fitting

Insulation

Removal Cost

Per Fitting

Approx.

Number of

Fittings to replace 69%

Replacement

Cost Per Fitting Base Price

Contractor

OH&P - 164%

Boiler Plant Elbow/Tee 72 88.40$ 130.00$ 50 695.18$ 50,483.65$ 82,793.19$ 133,276.85$

Boiler Plant Valve/PRV 0 0 0 0 6,785.00$ -$ -$ -$

Boiler Plant steam Trap 0 0 0 0 8,282.00$ -$ -$ -$

Boiler Plant 26,655.37$

Boiler Plant 788.11$

Boiler Plant 160,720.33$

Boiler Plant 16,072.03$

Boiler Plant 176,792.36$

Laundry Elbow/Tee 100 88.40$ 130.00$ 69 1,845.00$ 127,305.00$ 208,780.20$ 336,085.20$

Laundry Valve/PRV 5 0 0 5 6,785.00$ 33,925.00$ 55,637.00$ 89,562.00$

Laundry Steam Trap 0 0 0 0 6,785.00$ -$ -$ -$

Laundry 85,129.44$

Laundry 770.75$

Laundry 511,547.39$

Laundry 51,154.74$

Laundry 562,702.13$

Main Buidling Elbow/Tee 251 88.40$ 130.00$ 174 1,845.00$ 321,030.00$ 526,489.20$ 847,519.20$

Main Buidling Valve/PRV 45 0 0 45 6,785.00$ 305,325.00$ 500,733.00$ 806,058.00$

Main Buidling Steam Trap 12 0 0 12 6,785.00$ 81,420.00$ 133,528.80$ 214,948.80$

Main Buidling 373,705.20$

Main Buidling 770.75$

Main Buidling 2,243,001.95$

Main Buidling 224,300.20$

Main Buidling 2,467,302.15$

Basement Elbow/Tee 74 88.40$ 130.00$ 52 1,845.00$ 95,940.00$ 157,341.60$ 253,281.60$

Basement Valve/PRV 5 0 0 5 6,785.00$ 33,925.00$ 55,637.00$ 89,562.00$

Basement Steam Trap 0 0 0 0 6,785.00$ -$ -$ -$

Basement 68,568.72$

Basement 770.75$

Basement 412,183.07$

Basement 41,218.31$

Basement 453,401.38$

Penthouse Elbow/Tee 8 88.40$ 130.00$ 6 1,845.00$ 11,070.00$ 18,154.80$ 29,224.80$

Penthouse Valve/PRV 3 0 0 3 6,785.00$ 20,355.00$ 33,382.20$ 53,737.20$

Penthouse Steam Trap 0 0 0 0 6,785.00$ -$ -$ -$

Penthouse 16,592.40$

Penthouse 770.75$

Penthouse 100,325.15$

Penthouse 10,032.52$

Penthouse 110,357.67$

Total Project Probable Cost Including Escalation 2.03% per Annum 2028

Total Project Probable Cost Including Escalation 2.03% per Annum 2029

Total Project Probable Cost Including Escalation 2.03% per Annum 2030 4,169,123.80$

4,086,174.46$

4,004,875.48$

Total Project Probable Cost 3,770,555.68$

Total Project Probable Cost Including Escalation 2.03% per Annum 2026 3,847,097.96$

Total Project Probable Cost Including Escalation 2.03% per Annum 2027 3,925,194.04$

SDVOSB Premium (20%)

Material Premium (5%)

Sub Total

A/E Design Fee (10%)

Total

SDVOSB Premium (20%)

Material Premium (5%)

Sub Total

A/E Design Fee (10%)

Total

SDVOSB Premium (20%)

Material Premium (5%)

Sub Total

A/E Design Fee (10%)

Total

SDVOSB Premium (20%)

Material Premium (5%)

Sub Total

A/E Design Fee (10%)

Total

SDVOSB PREMIUM (20%)

MATERIAIL PREMIUM (5%)

SUB TOTAL

A/E DESIGN FEE (10%)

Total

BOILER START UP PROCEDURE REVIEW & RECOMMENDATIONS

As noted in the backgrounds section of this report, the investigations found that the cause for the incident could be attributed to a lack of proper standard operating procedures, lack of adequate training, lack of oversight, and non-compliance with several OSHA regulations.

KSM strongly recommends the following documentation and procedures be developed and or maintained onsite and accessible to any staff member who will work with the steam systems per

29 CFR 1910 & 1960:

1. Well documented lockout-tagout procedure with established notification channels to alert all appropriate staff when work is being performed, and where it’s being performed.

a. San Juan did not provide any documentation with this information.

2. Complete orderly shutdown procedures to reduce hazards to employees as a result of equipment stoppage.

a. San Juan did not provide any documentation with this information.

3. Well documented procedures for relieving the system, or sections of the system when isolated, of all stored energy when any section of the system is disconnected, restrained, or rendered safe after lockout-tagout isolating devices have been applied.

a. Current startup procedure is missing steps referring to bleeding the system prior to start up.

b. Current startup procedure does not go in depth on any step and may lead to confusion resulting in a dangerous start up.

c. Current start up procedure does not provide operators with any indicators or sounds operators should be aware of when starting up the system that may be signs of an impending catastrophic failure.

4. Develop standard operating procedure for appropriate staff notification when system is being serviced by non-VA staff or outside contractors.

a. San Juan did not provide any documentation with this information.

5. Testing procedures for periodic testing of condensate return system and components.

a. San Juan did not provide any documentation with this information.

6. Procedures for steam traps, condensate pumps, and piping routine maintenance checks and servicing.

a. San Juan did not provide any documentation with this information.

7. Published procedures for proper reporting and documentation of system leaks.

a. San Juan did not provide any documentation with this information.

8. Published standard training procedures for supervisors and staff for proper health and safety procedures when working with steam systems.

a. San Juan did not provide any documentation with this information.

9. Develop complete procedures for training staff on all operations, shutdowns, startups, maintenance, isolating sections, de-energizing system, draining, relieving pressure, etc.

and develop comprehensive testing to ensure comprehension and retention of training prior to employing in any position where interaction with the steam system is likely to transpire.

a. This is akin to any standard certification process.

b. San Juan did not provide any documentation with this information.

In addition to the above 29 CFR 1910 & 1960 requirements, KSM recommends that the aforementioned procedures be audited and updated annually by the manufacturer, VA FMS supervisor, plant supervision staff to ensure the most up-to-date procedures are well documented. Also, KSM recommends development of a continuing education process to ensure all staff are adequately trained and current with all standard procedures.

All documentation should also include the manufacturer’s standard warm-up curves and ensure that they are displayed and followed. For cold starts, the warm-up curve does not increase the boiler water temperature over 100 degrees F per hour.

PHOTOGRAPHS OF TEST POINTS

Point 1 Valve

Point 2 Tee

Point 3 Tee

Point 4 Tee (Omitted)

Point 5 Tee

Point 6 Elbow

Point 7 Elbow

Point 8 Elbow

Point 9 Wye Strainer

Point 10 Union

Point 11 Elbow

Point 12 Elbow

Point 13 Valve

Point 14 Tee

Point 15 Elbow

Point 16 Valve

Point 17 Valve

Point 18 Valve

Point 19 Valve

Point 20 Valve

Point 21 Valve

Point 22 Elbow

Point 23 Elbow

Point 24 Elbow

Point 25 Elbow

Point 26 Elbow

Point 27 Tee

Point 28 Elbow

Point 29 Elbow

Point 30 Elbow

Point 31 Elbow

Point 32 Elbow

Point 33 Elbow

Point 34 Elbow

Point 35 Elbow

Point 36 Tee

Point 37 Elbow

Point 38 Elbow

Point 39 Elbow

Point 40 Elbow

Point 41 Elbow

Point 42 Elbow

Point 43 Elbow

Point 44 Valve

APPENDIX A

Melanie S. Griffin,SecretaryRon DeSantis, Governor

STATE OF FLORIDA

BOARD OF PROFESSIONAL ENGINEERS

THE PROFESSIONAL ENGINEER HEREIN IS LICENSED UNDER THE

PROVISIONS OF CHAPTER 471, FLORIDA STATUTES

KEITH, DAVID RYAN JAMES

Do not alter this document in any form.

2011 27TH AVE N

LICENSE NUMBER: PE85291

EXPIRATION DATE: FEBRUARY 28, 2025

This is your license. It is unlawful for anyone other than the licensee to use this document.

ST. PETERSBURG FL 33713

Always verify licenses online at MyFloridaLicense.com https://www.myfloridalicense.com/LicenseDetail.asp?SID=&id=5867df35fb1842f5ac7f4af23cc9cc33

BOARD OF PROFESSIONAL ENGINEERS

THE PROFESSIONAL ENGINEER HEREIN IS LICENSED UNDER THE

PROVISIONS OF CHAPTER 471, FLORIDA STATUTES

KEITH, DAVID RYAN JAMES

Do not alter this document in any form.

2011 27TH AVE N

LICENSE NUMBER: PE85291

EXPIRATION DATE: FEBRUARY 28, 2025

This is your license. It is unlawful for anyone other than the licensee to use this document.

ST. PETERSBURG FL 33713

https://www.myfloridalicense.com/LicenseDetail.asp?SID=&id=5867df35fb1842f5ac7f4af23cc9cc33

BOARD OF PROFESSIONAL ENGINEERS

THE PROFESSIONAL ENGINEER HEREIN IS LICENSED UNDER THE

PROVISIONS OF CHAPTER 471, FLORIDA STATUTES

STEPHENSON, NICHOLAS PAUL

Do not alter this document in any form.

7403 WILD OAK LANE

LICENSE NUMBER: PE83283

EXPIRATION DATE: FEBRUARY 28, 2025

This is your license. It is unlawful for anyone other than the licensee to use this document.

LAND O LAKES FL 34637

https://www.myfloridalicense.com/LicenseDetail.asp?SID=&id=badb445eb645f222f805071a50fb32b4

APPENDIX B

APPENDIX C

Boiler Start Up Procedures

VHA San Juan

There are 3 Boiler, only one Boiler will handle the load. One is operating, the other two are kept warm or maintenance and inspection.

Cold Boiler Start Up and Place online.

Walk around the Boiler to check Boiler integrity.

Fill Boiler with water and look for leaks.

Check Boiler system alignment.

Air Atomizing valves and piping

Diesel fuel valves and piping

Propane gas valves and piping

Electrical power

Start up the Boiler, observe flame pattern and stability.

Let Boiler warm up on low fire till the Boiler reaches Operating steam pressure (this may take 24 hours if

Boiler has newly installed refractory)

Perform Boiler Safety test.

When the Hospital steam system has not pressure, filling the steam system will take between 30 and

60min to properly fill the system, and personnel should be posted at different points to drain the condensate and verify for leaks. Quickly shut the valve if water vibration or water hammer occurs.

With Boiler warm up, drain condensate from Main Steam valve, and proceed to slowly open the Main

Steam valve, equalizing pressure on both side of the valve.

Hot Boiler

Walk around the Boiler to check Boiler integrity.

Check Boiler water level and Feed water system.

Check Boiler system alignment:

Air Atomizing

Diesel Fuel system

Propane gas

Electrical power

Start Up the Boiler on low fire, verify flame stability and bring Boiler to operating pressure.

When the Hospital steam system has not pressure, filling the steam system will take between 30 and

60min to properly fill the system, and personnel should be posted at different points to drain the condensate and verify for leaks. Quickly shut the valve if water vibration or water hammer occurs.

With Boiler at operational pressure, drain condensate from Main Steam valve, and proceed to slowly open the Main Steam valve, equalizing pressure on both side of the valve.

APPENDIX D

Miami VAMC Boiler Plant

Boiler Plant Normal Operating

Procedures

NOP 01-P

Procedure for Boiler Bottom Blowdown

Procedure Created: January 1, 2024 Procedure Expires: December 31, 2028

Directive: 1810

Conduct this procedure for the Front and the Rear Blowdown Lines.

1. Open the downstream Hand-wheel valve wide open.

2. Fully open the upstream valve for a 3 to 5 second burst.

3. After the 3 to 5 second burst, close the upstream valve.

4. Close the downstream valve.

NOP 02-P

Procedure to Bypass Water Softener

1. Ensure that all on-line boilers have adequate residual levels of scale preventive chemical.

2. Locate and fully close the manual valve on city water line feeding water softener and manual valve leaving the softener.

3. Fully open the manual bypass valve to supply hard city water.

NOP 03-P

Procedure to Regenerate Water Softener

1. Check salt level in Brine Tank. Ensure adequate salt is available, without exceeding maximum level.

2. On Softener control panel, press the "Extra Cycle" button for 5-seconds, to initiate a Manual

Regeneration.

NOP 04-P

Procedure for Water Column and Sight Glass Blowdown

● Deaerator and Condensate Tank Sight Glass Blowdown

1. Locate bottom sight glass.

2. Close bottom red handled isolation valve.

3. Open ball valve below red handled isolation valve and allow sight glass to drain.

4. Close ball valve.

5. Open bottom red handled isolation valve. Water level should reestablish.

● Boiler Sight Glass Blowdown

1. Locate sight glass on boiler. Ensure that drain line is piped to a safe location.

2. Open the valve below the sight glass in the sight glass drain plumbing.

3. Allow water to drain to a level approximately half-way between normal water level and the bottom of the glass.

4. Close the valve, quickly. Water level should return quickly to previous location.

● Boiler Float (LWCO) Water Column Blowdown

1. Locate the float water column.

2. Press and hold the float shunt switch.

3. Open the float water column blowdown ball valve.

4. Let the valve remain open a few seconds. Boiler should continue to fire as long as shunt button is engaged.

5. Close the float water column blowdown valve, then release the shunt switch.

NOP 04-P

● Boiler Probe (ALWCO) Water Column Blowdown

1. Locate the probe water column.

2. Press and hold the probe shunt switch.

3. Open the probe water column blowdown ball valve.

4. Let the valve remain open for a few seconds.

5. Close the probe water column blowdown ball valve, then release the shunt.

NOP 05-P

Procedure for Boiler Shutdown

1. On the Hays Cleveland control panel for the boiler to be shut down, go to the Combustion

Loops page, and place the Sub-master Control in Manual- then reduce the firing rate to

Zero.

2. Locate the boiler control on/off switch.

3. Switch boiler to off. Verify post purge is completed.

4. Close manual shutoff valves in natural gas and / or oil fuel trains.

5. Secure / Close Feedwater Valve to boiler.

6. Close Main Steam Stop Valve on top of boiler.

7. Close Secondary Steam Stop Valve on top of boiler.

8. Allow boiler pressure to decrease down to zero.

9. Open the boiler vent.

6,7

NOP 06-P

Procedure for Normal Hot Boiler Startup Firing Natural Gas

1. Locate water level sight glass.

a. View water level in sight glass to verify proper water level.

i. Water level should be within the sight glass.

b. Blowdown the sight glass to visually check good water level communication.

c. DO NOT ATTEMPT TO START BOILER IF WATER LEVEL IS NOT VISIBLE IN SIGHT GLASS.

2. Locate Natural Gas Train going into the Boiler.

a. Verify all main gas manual valves are open.

b. Verify all pilot gas manual valves are open.

3. Locate Feedwater lines going into boiler.

a. Verify feedwater valves are open.

b. Verify feedwater bypass is closed.

4. Verify safety devices are reset and LOO (lock open only) valves are locked open.

5. On the Control Panel on the Boiler:

a. Verify the Fan Control Switch is set to Auto.

b. Turn the Burner Switch to Gas.

6. Verify on the Fireye display panel that the boiler goes through a normal pre-purge and light-off.

7. Verify Primary and Secondary Boiler Steam Stop Valves are open.

8. On the Hays Cleveland control panel, set the desired firing rate (manual) or place firing rate control in

Automatic. Place the Drum Level Control in Automatic.

NOP 07-P

Procedure for Placing Cold Steam Lines in Service

1. Locate and open all condensate drains in the cold steam line.

2. Let condensate fully drain from cold steam line.

3. Slightly crack steam supply valve to cold line. Use Warm-up/bypass valve if available.

4. Allow steam to slowly heat cold line.

5. When only steam is flowing from all condensate drains, close all condensate drains.

6. Allow steam pressure in line to slowly build. Continue to slowly open steam supply valve to finish heating line and bring the steam line into service.

NOP 08-P

Procedure for Long Term Boiler Storage -Wet Layup

1. Bring boiler to Low Fire, in Manual, using the Hays Cleveland Control panel.

2. Waterside Wet Storage

a. Add Sodium Sulfite (oxygen scavenger) until a residual sulfite level of not less than 100 ppm is present in the Boiler Water. Ensure that the Total Alkalinity in the Boiler Water is not less than 450 ppm.

b. Start the boiler, build to normal steam pressure, and fire for an additional 15-minutes.

c. Shutdown the boiler.

d. Close both steam stop valves.

e. When the boiler cools, completely fill the boiler with water.

f. Open the boiler vent valve, and add additional feedwater until the water level reaches the top of the stand-pipe.

g. Close the vent valve once the boiler cools to room temperature.

3. Check water chemistry for proper sulfite and alkalinity residual at least once each week.

4. Fireside Storage

a. For long term storage, apply a light coating of oil to fireside tube metal surfaces and/or leave fireside doors open and allow the space to draft if dry conditions are present. If doors are left closed, use a desiccant material to absorb moisture.

NOP 09-P

Procedure for Cold Boiler / Cold Header Line / Cold Main Steam Header Startup

Firing Natural Gas

1. Locate water level sight glass.

a. View water level in sight glass to verify proper water level.

i. Water level should be within the sight glass.

b. Blowdown the sight glass to visually check good water level communication.

c. DO NOT ATTEMPT TO START BOILER IF WATER LEVEL IS NOT VISIBLE IN SIGHT

GLASS.

2. Locate Natural Gas Train going into the Boiler.

a. Verify all main gas manual valves are open.

b. Verify all pilot gas manual valves are open.

3. Locate Feedwater lines going into boiler.

a. Verify feedwater valves are open.

b. Verify feedwater bypass is closed.

4. Locate and open Boiler Vent Valve.

5. Boiler Main Steam Stop Valves should be open.

6. Boiler header valve should be open.

7. Open any condensate drains in header line in between the boiler and the main header to drain any trapped condensate.

8. Open condensate drain in main steam header.

9. Open any other condensate drains throughout the system.

10. Verify safety devices are reset and LOO (lock open only) valves are locked open.

11. On the Hays Cleveland Control panel, verify that the firing rate control is set for

"Manual", and low fire (0%).

12. On the Control Panel on the Boiler:

a. Verify fuel select is set to Natural Gas.

b. Turn the Burner Switch to On

13. Verify on the Fireye display panel that the boiler goes through a normal pre-purge and light-off.

14. Boiler control should remain in manual mode and should remain in low fire.

15. Boiler should be allowed to warm up at no more than 100°F per hour.

16. Once steam pressure reaches 25 psig, close the boiler vent, and all other condensate drains.

17. Once steam pressure in the boiler and system reaches operating pressure, place the boiler control in automatic and proceed with normal operation.

NOP 10-P

Procedure for Cold Boiler / Cold Header Line / Hot Main Steam Header Startup

Firing Natural Gas

1. Locate water level sight glass.

a. View water level in sight glass to verify proper water level.

i. Water level should be within the sight glass.

b. Blowdown the sight glass to visually check good water level communication.

c. DO NOT ATTEMPT TO START BOILER IF WATER LEVEL IS NOT VISIBLE IN SIGHT

GLASS.

2. Locate Natural Gas Train going into the Boiler.

a. Verify main gas manual valves properly aligned.

b. Verify all pilot gas manual valves are properly aligned.

3. Locate Feedwater lines going into boiler.

a. Verify feedwater valves are open.

b. Verify feedwater bypass is closed.

4. Locate and open Boiler Vent Valve.

5. Boiler Main Steam Stop Valve should be closed.

6. Secondary Steam Stop Valve to header should be closed.

7. Open any condensate drains in cold header line in between the boiler and Stop Valves to drain any trapped condensate.

8. On the Hays Cleveland Control panel, verify that the firing rate control is set for

"Manual", and low fire (0%).

9. On the Control Panel on the Boiler:

a. Verify fuel select is set to Natural Gas.

b. Turn the Burner Switch to On

10. Verify on the Fireye display panel that the boiler goes through a normal pre-purge and light-off.

11. Boiler control should remain in manual mode and should remain in low fire.

12. Boiler should be allowed to warm up at no more than 100°F per hour.

13. SLOWLY crack the Header valve to allow the header line to be reheated.

14. When only steam is venting from the condensate drain between the second main steam stop on the boiler and the header valve, close the condensate drain.

15. Once steam pressure reaches 25 psig, close the boiler vent.

16. Allow steam pressure in the boiler to increase to 75% to 80% of the main steam header pressure.

17. Once steam pressure in the boiler reaches 75% to 80% of main steam header pressure, slowly open the main steam stop valves on the boiler.

18. Place the boiler control in automatic and proceed with normal operation.

NOP 11-P

Procedure for Boiler Takedown for Inspection

1. Shutdown the boiler.

2. Close Main Steam Stop Valve and Secondary Steam Stop Valve.

3. Allow boiler to cool until pressure in the boiler is zero.

4. Open boiler vent.

5. Close Feedwater Valve to the boiler.

6. Open boiler blowdown and fully drain the boiler.

7. REFER TO LOCK OUT TAG OUT PROCEDURES FOR BOILER.

8. Secure and Lock Out Electrical Power to Boiler System.

9. Secure and Lock out Natural Gas Train into the boiler.

10. Secure and Lockout Fuel Oil Train into the boiler.

11. Secure and Lockout Feedwater into the boiler.

12. Secure and Lockout Blowdown from the boiler.

13. Secure and Lockout any chemical feed into the boiler.

14. Secure and Lockout Main Steam Stops on top of the boiler.

15. Secure and Lockout Stack Connection to Common Flue.

16. Disconnect all piping and other…