IPL Type 1 IPL Type 2

Corp.
Credits
CVO
Credit
IPL Type-1 Remark
Pressure Relief Device Only No isolation valves
Clean Service. Well designed, fabricated, installed and tested.
Testing documented. 4 4 PSV - Clean Service_1 Relief Device Only (No Isolation Valves)
Dirty Service (dirt, corrosion, polymerizing product, etc.) 2 4 PSV - Dirty Service_1 Relief Device Only (No Isolation Valves)
Well designed, fabricated, installed and tested. Testing
documented.
Dual Pressure Relief Devices in parallel w/ 3-way valve
or captive key isolation valve
Clean Service. Well designed, fabricated, installed and tested.
Testing documented. 4 5 PSV - Clean Service_2
Spare Relief Device in Parallel with 3 Way Mechanically
Linked Selector Valves or Keyed Isolation Valves per RSM
Criteria (to be developed)
Dirty Service (dirt, corrosion, polymerizing product, etc.) 2 4 PSV - Dirty Service_2
Spare Relief Device in Parallel with 3 Way Mechanically
Linked Selector Valves or Keyed Isolation Valves per RSM
Criteria (to be developed)
Well designed, fabricated, installed and tested. Testing
documented.
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure
Clean Service. Well designed, fabricated, installed and tested.
Testing documented.
3 3 PSV - Clean Service_3
Relief Device (Inlet Isolation Valve (CSO) / No Outlet
Isolation Valve)
Dirty Service (dirt, corrosion, polymerizing product, etc.) 2 3 PSV - Dirty Service_3
Relief Device (Inlet Isolation Valve (CSO) / No Outlet
Isolation Valve)
Well designed, fabricated, installed and tested. Testing
documented.
Dirty Service (dirt, corrosion, polymerizing product, etc.) 2 3 PSV - Dirty Service_4 Relief Device (Inlet and Outlet Isolation Valves) (CSO)
Well designed, fabricated, installed and tested. Testing
documented.
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure & installed
outlet spectacle blind
Clean Service. Well designed, fabricated, installed and tested.
Testing documented.
3 3 PSV - Clean Service_5
Relief Device (Inlet Isolation Valve (CSO) and Installed
Spectacle Blind on Outlet)
Dirty Service (dirt, corrosion, polymerizing product, etc.) 2 3 PSV - Dirty Service_5
Relief Device (Inlet Isolation Valve (CSO) and Installed
Spectacle Blind on Outlet)
Well designed, fabricated, installed and tested. Testing
documented.
Clean service. 3 Rupture Disk - Clean Service_6 Rupture Disk - Clean Service
Well designed, fabricated, installed and tested. Testing
documented.
Difficult application (dirt, corrosion, polymerizing product, etc.) 2 Rupture Disk - Dirty Service_6 Rupture Disk - Dirty Service
Well designed, fabricated, installed and tested. Testing
documented.
Mechanical over-speed protection
Tested regularly according to vendor prescription and freq.
depending on test results. Testing documented.
1 1 Mechanical Overspeed Trip Mechanical Overspeed Trip
Car sealing or chain locking manual valve
Car seals or chain locking is only used for scenarios where mis-
operation of the valve is the initiating event.
1 1 CSO Valve(s) Car Sealed Open Valve(s) or Chain Locking manual valve
Clean service. Suited for application. 1 Check Valve_1 Clean service. Suited for application.
Well designed, fabricated, installed and with documented testing
at least annually.
The future test interval can be modified depending on success of
conducted tests.
Check valve Scenario related to large backflow only, not leakage. 1 1 Check Valve_2 Scenario related to large backflow only, not leakage.
Double check valve Scenario related to large backflow only, not leakage. 2 2 Double Check Valve
Double Check Valve, Scenario related to large backflow
only, not leakage.
Restriction orifice
Clean, non-corrosive, and non-erosive service which will
effectively restrict flow to less than the specified flow-rate under
all conditions and upstreampressures.
2 2 Restiction Orifice
Clean, non-corrosive, and non-erosive service which will
effectively restrict flow to less than the specified flow-rate
under all conditions and upstreampressures.
Excess flow valve Clean service, scenario related to excess flow rate. 1 1 Excess Flow Valve Clean service, scenario related to excess flow rate.
BPCS control loop (DCS or PLC) Per IEC-61511, maximumIPL credit is 1. 1 1 BPCS Control Loop (DCS or PLC) Per IEC-61511, maximumIPL credit is 1.
BPCS Automatic control loop
Failure is not an initiating event contributor and sensors/final
control elements are properly maintained.
1 1 BPCS Automatic control Loop
Failure is not an initiating event contributor and
sensors/final control elements are properly maintained.
BPCS Manual control loop
Greater than 5 minutes available for response. Failure is not an
initiating event contributor and sensors/final control elements
are properly maintained.
1 1 BPCS - Manual Control Loop
Greater than 5 minutes available for response. Failure is
not an initiating event contributor and sensors/final control
elements are properly maintained.
Single BPCS loop
No human intervention required. Must be independent of all
other IEs and IPLs. (LOPA Book Approach A)
1 1 Single BPCS Loop (LOPA Appr A)
No human intervention required. Must be independent of
all other IEs and IPLs. (LOPA Book Approach A)
Single BPCS loop
No human intervention required. Maximumof 1 additional BPCS
credit per scenario. BPCS motherboard is the only component
shared with any other IEs or IPLs. (LOPA Book Approach B)
1 1 Single BPCS Loop (LOPA Appr B)
No human intervention required. Maximumof 1 additional
BPCS credit per scenario. BPCS motherboard is the only
component shared with any other IEs or IPLs. (LOPA Book
Approach B)
Pneumatic control loop
Failure is not an initiating event contributor and sensors/final
control elements are properly maintained.
1 1 Pneumatic Control Loop
Failure is not an initiating event contributor and
sensors/final control elements are properly maintained.
Pressure regulator Manually adjusted spring-tension device. 1 1 Pressure Regulator Manually adjusted spring-tension device.
SIL 1 interlock All in accordance to IEC-61508 and IEC-61511. 1 1 SIL Class 1 Primary Interlock
SIL 2 interlock All in accordance to IEC-61508 and IEC-61511. 2 2 SIL Class 2 Primary Interlock
SIL 3 interlock All in accordance to IEC-61508 and IEC-61511. 3 3 SIL Class 3 Primary Interlock
Operator response
Operator to follow an emergency response procedure under
high stress (life endangering) with less than five minutes to
diagnosis the problem, determine a course of action and
respond.
0 0 Operator response_1
Operator to follow an emergency response procedure
under high stress (life endangering) with less than five
minutes to diagnosis the problem, determine a course of
action and respond.
Operator response
Simple, well-documented action with clear and reliable
indications that the action is required with 10 minute or greater
response time.
1 0 Operator response_2
Simple, well-documented action with clear and reliable
indications that the action is required with 10 minute or
greater response time.
Manual operator response in field
> 10 minutes to respond. Provided sensors/alarms are tested
and operator training includes required response. 1 0 Manual operator response in field
> 10 minutes to respond. Provided sensors/alarms are
tested and operator training includes required response.
Operator response to annunciator
> 10 minutes to respond in the field or > 5 minutes to respond in
the control room. No distractions fromother alarms. 1 0 Operator response to annunciator
> 10 minutes to respond in the field or > 5 minutes to
respond in the control room. No distractions fromother
alarms.
Operator response to field reading or sample analysis
Time between field readings or sample results is at least twice
the time expected for an initiating event to propagate to the
consequence.
1 1
Operator response to field reading or sample
analysis
Time between field readings or sample results is at least
twice the time expected for an initiating event to propagate
to the consequence.
Human double-check
As specified in written procedure, independent work group with
incentives
1 1 Human double-check
As specified in written procedure, independent work group
with incentives
Normal operator procedure Simple, well-documented action. 1 1 Normal operator procedure Simple, well-documented action.
Instrumented double mechanical seal
As long as the seal measurement includes either regular
monitoring by procedure or an alarmto indicate single seal
failure and a procedure for repair on failure of one seal.
1 1 Instrumented double mechanical seal
As long as the seal measurement includes either regular
monitoring by procedure or an alarmto indicate single seal
failure and a procedure for repair on failure of one seal.
Special operator procedure
Failure of a two person checklist procedure (done-by, checked-
by) that has fewer than 10 major steps with a minimumof 40
minutes allowed to detect and correct errors.
1 1 Special operator procedure
Failure of a two person checklist procedure (done-by,
checked-by) that has fewer than 10 major steps with a
minimumof 40 minutes allowed to detect and correct
errors.
Dikes, fire walls, containment, etc.
Design and implementation must be in accordance to applicable
standards. Regular inspection and maintenance is required and
documented.
2 2
Secondary Containment, such as dike, Fire walls
(per PHA)
Design and implementation must be in accordance to
applicable standards. Regular inspection and maintenance
is required and documented.
Eliminates the potential for flashback through a piping system
into a vessel, tank or atmosphere. 2 4 Flame or Detonation Arrestors - Clean Service
Eliminates the potential for flashback through a piping
systeminto a vessel, tank or atmosphere. PFD is based on
proper design, installation and maintenance. Clean service.
PFD is based on proper design, installation and maintenance.
Clean service. 2 4 Flame or Detonation Arrestors - Clean Service
Eliminates the potential for flashback through a piping
systeminto a vessel, tank or atmosphere. PFD is based on
proper design, installation and maintenance. Clean service.
Detonation Arrestors Fouling or difficult service. 1 0 Detonation Arrestors - Dirty Service Fouling or difficult service.
Flame arrestor Provided maintained routinely 1 4 Flame Arrestor Provided maintained routinely
Will prevent overpressure. 3 2 Open Vent (no valve) Will prevent overpressure. Clean service
Clean service. 3 2 Open Vent (no valve) Will prevent overpressure. Clean service
Overflow Line No obstructions 3 3 Overflow Line No obstructions
Blast-wall/Bunker
Will protect equipment, buildings, and people against
blast/explosion.
3 3 Blast-wall/Bunker
Will protect equipment, buildings, and people against
blast/explosion.
Fireproofing
Reduces heat input and provides additional time for
depressurizing/fire fighting/etc.
2 2 Fireproofing
Reduces heat input and provides additional time for
depressurizing/fire fighting/etc.
Special PPE 1 1 Special PPE Special PPE
Minimal Fireproofing 0
Fireproofing on major supports and piperacks 0
Fireproofing per company standards 0
Minimal Fireproofing 0
Fireproofing on major supports and piperacks 1
Fireproofing per company standards 1
Minimal Fireproofing 1
Fireproofing on major supports and piperacks 1
Fireproofing per company standards 2
Minimal Fireproofing 2
Fireproofing on major supports and piperacks 2
Fireproofing per company standards 3
Shorthand Version of IPL Remarks
CVO
Credit
Corp.
Credits
IPL Type 1 IPL Type 2
CSC Valve(s) Car Sealed Closed Valve(s) or Chain locking manual valve 1 1 Car sealing or chain locking manual valve
Car seals or chain locking is only used for scenarios where
mis-operation of the valve is the initiating event.
0
CSO Valve(s) Car Sealed Open Valve(s) or Chain Locking manual valve 1 1 Car sealing or chain locking manual valve
Car seals or chain locking is only used for scenarios where
mis-operation of the valve is the initiating event.
0
Mech Integrity
Mechanical Integrity Inspection (must be procedurally driven -
i.e., helogen testing heat exchangers)
1 1
PPE Personal Protective Equipment 1 1 Special PPE -- 0
Proc Intervention_1 Procedural Intervention (inspections, rounds, etc.) 1 1
Proc Intervention_2 Procedural intervention w/ > 40 min available 2 2
PSV - Clean Service_1 Relief Device Only (No Isolation Valves) 5 4 Pressure Relief Device Only No isolation valves
Clean Service. Well designed, fabricated, installed and
tested. Testing documented.
1
PSV - Clean Service_2
Spare Relief Device in Parallel with 3 Way Mechanically Linked
Selector Valves or Keyed Isolation Valves per RSMCriteria (to be
developed)
5 4
Dual Pressure Relief Devices in parallel w/ 3-way
valve or captive key isolation valve
Clean Service. Well designed, fabricated, installed and
tested. Testing documented.
1
PSV - Clean Service_3
Relief Device (Inlet Isolation Valve (CSO) / No Outlet Isolation
Valve)
3 3
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure
Clean Service. Well designed, fabricated, installed and
tested. Testing documented.
0
PSV - Clean Service_4 Relief Device (Inlet and Outlet Isolation Valves) (CSO) 3 3
PSV - Clean Service_5
Relief Device (Inlet Isolation Valve (CSO) and Installed Spectacle
Blind on Outlet)
3 3
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure & installed
outlet spectacle blind
Clean Service. Well designed, fabricated, installed and
tested. Testing documented.
0
PSV - Dirty Service_1 Relief Device Only (No Isolation Valves) 4 2 Pressure Relief Device Only No isolation valves Dirty Service (dirt, corrosion, polymerizing product, etc.) 2
PSV - Dirty Service_2
Spare Relief Device in Parallel with 3 Way Mechanically Linked
Selector Valves or Keyed Isolation Valves per RSMCriteria (to be
developed)
4 2
Dual Pressure Relief Devices in parallel w/ 3-way
valve or captive key isolation valve
Dirty Service (dirt, corrosion, polymerizing product, etc.) 2
PSV - Dirty Service_3
Relief Device (Inlet Isolation Valve (CSO) / No Outlet Isolation
Valve) 3 2
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure
Dirty Service (dirt, corrosion, polymerizing product, etc.) 1
PSV - Dirty Service_4 Relief Device (Inlet and Outlet Isolation Valves) (CSO) 3 2
Pressure Relief Device with inlet and outlet
isolation valves controlled by administrative
procedure
Dirty Service (dirt, corrosion, polymerizing product, etc.) 1
PSV - Dirty Service_5
Relief Device (Inlet Isolation Valve (CSO) and Installed Spectacle
Blind on Outlet) 3 2
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure & installed
outlet spectacle blind
Dirty Service (dirt, corrosion, polymerizing product, etc.) 1
PVRV - Clean Service_1 Relief Device Only (No Isolation Valves) 5 5
PVRV - Clean Service_2
Spare Relief Device in Parallel with 3 Way Mechanically Linked
Selector Valves or Keyed Isolation Valves per RSMCriteria (to be
developed)
5 5
PVRV - Clean Service_3 Relief Device (Inlet Isolation Valve / No Outlet Isolation Valve) 3 3
PVRV - Clean Service_4 Relief Device (Inlet and Outlet Isolation Valves) 3 3
PVRV - Clean Service_5
Relief Device (Inlet Isolation Valve and Installed Spectacle Blind
on Outlet)
3 3
PVRV - Dirty Service_1 Relief Device Only (No Isolation Valves) 4 4
PVRV - Dirty Service_2
Spare Relief Device in Parallel with 3 Way Mechanically Linked
Selector Valves or Keyed Isolation Valves per RSMCriteria (to be
developed)
4 4
PVRV - Dirty Service_3 Relief Device (Inlet Isolation Valve / No Outlet Isolation Valve) 3 3
PVRV - Dirty Service_4 Relief Device (Inlet and Outlet Isolation Valves) 3 3
PVRV - Dirty Service_5
Relief Device (Inlet Isolation Valve and Installed Spectacle Blind
on Outlet)
3 3
Rupture Disc - Clean Service_1 Relief Device Only (No Isolation Valves) 5 3 Rupture disc Clean service. 2
Rupture Disc - Clean Service_2
Spare Relief Device in Parallel with 3 Way Mechanically Linked
Selector Valves or Keyed Isolation Valves per RSMCriteria (to be
developed)
5 5
Rupture Disc - Clean Service_3 Relief Device (Inlet Isolation Valve / No Outlet Isolation Valve) 3 3
Rupture Disc - Clean Service_4 Relief Device (Inlet and Outlet Isolation Valves) 3 3
Rupture Disc - Clean Service_5
Relief Device (Inlet Isolation Valve and Installed Spectacle Blind
on Outlet)
3 3
Rupture Disc - Dirty Service_1 Relief Device Only (No Isolation Valves) 4 2 Rupture disc
Difficult application (dirt, corrosion, polymerizing product,
etc.)
2
Rupture Disc - Dirty Service_2
Spare Relief Device in Parallel with 3 Way Mechanically Linked
Selector Valves or Keyed Isolation Valves per RSMCriteria (to be
developed)
4 4
Rupture Disc - Dirty Service_3 Relief Device (Inlet Isolation Valve / No Outlet Isolation Valve) 3 3
Rupture Disc - Dirty Service_4 Relief Device (Inlet and Outlet Isolation Valves) 3 3
Rupture Disc - Dirty Service_5
Relief Device (Inlet Isolation Valve and Installed Spectacle Blind
on Outlet)
3 3
PSV - Clean Service_6 Pressure Relief Device - Clean Service 3 4 Pressure Relief Device Only No isolation valves
Clean Service. Well designed, fabricated, installed and
tested. Testing documented.
-1
PSV - Dirty Service_6 Pressure Relief Device - Dirty Service 2 2 Pressure Relief Device Only No isolation valves Dirty Service (dirt, corrosion, polymerizing product, etc.) 0
Rupture Disk - Clean Service_6 Rupture Disk - Clean Service 3 3 Rupture disc Clean service. 0
Rupture Disk - Dirty Service_6 Rupture Disk - Dirty Service 2 2 Rupture disc
Difficult application (dirt, corrosion, polymerizing product,
etc.)
0
Mechanical Overspeed Trip Mechanical Overspeed Trip 1 1 Mechanical over-speed protection
Tested regularly according to vendor prescription and freq.
depending on test results. Testing documented.
0
Check Valve_1 Clean service. Suited for application. 1 1 Check valve Clean service. Suited for application. 0
Check Valve_2 Scenario related to large backflow only, not leakage. 1 1 Check valve Scenario related to large backflow only, not leakage. 0
Double Check Valve
Double Check Valve, Scenario related to large backflow only, not
leakage.
2 2 Double check valve Scenario related to large backflow only, not leakage. 0
Restiction Orifice
Clean, non-corrosive, and non-erosive service which will
effectively restrict flow to less than the specified flow-rate under
all conditions and upstreampressures.
2 2 Restriction orifice
Clean, non-corrosive, and non-erosive service which will
effectively restrict flow to less than the specified flow-rate
under all conditions and upstreampressures.
0
Excess Flow Valve Clean service, scenario related to excess flow rate. 1 1 Excess flow valve Clean service, scenario related to excess flow rate. 0
SIL Class 3 Primary Interlock 3 3 SIL 3 interlock All in accordance to IEC-61508 and IEC-61511. 0
SIL Class 2 Primary Interlock 2 2 SIL 2 interlock All in accordance to IEC-61508 and IEC-61511. 0
SIL Class 1 Primary Interlock 1 1 SIL 1 interlock All in accordance to IEC-61508 and IEC-61511. 0
BPCS Control Loop (DCS or PLC) Per IEC-61511, maximumIPL credit is 1. 1 1 BPCS control loop (DCS or PLC) Per IEC-61511, maximumIPL credit is 1. 0
BPCS Automatic control Loop
Failure is not an initiating event contributor and sensors/final
control elements are properly maintained.
1 1 BPCS Automatic control loop
Failure is not an initiating event contributor and
sensors/final control elements are properly maintained.
0
BPCS - Manual Control Loop
Greater than 5 minutes available for response. Failure is not an
initiating event contributor and sensors/final control elements
are properly maintained.
1 1 BPCS Manual control loop
Greater than 5 minutes available for response. Failure is
not an initiating event contributor and sensors/final control
elements are properly maintained.
0
Single BPCS Loop (LOPA Appr A)
No human intervention required. Must be independent of all
other IEs and IPLs. (LOPA Book Approach A)
1 1 Single BPCS loop
No human intervention required. Must be independent of
all other IEs and IPLs. (LOPA Book Approach A)
0
Single BPCS Loop (LOPA Appr B)
No human intervention required. Maximumof 1 additional BPCS
credit per scenario. BPCS motherboard is the only component
shared with any other IEs or IPLs. (LOPA Book Approach B)
1 1 Single BPCS loop
No human intervention required. Maximumof 1 additional
BPCS credit per scenario. BPCS motherboard is the only
component shared with any other IEs or IPLs. (LOPA Book
Approach B)
0
Pneumatic Control Loop
Failure is not an initiating event contributor and sensors/final
control elements are properly maintained.
1 1 Pneumatic control loop
Failure is not an initiating event contributor and
sensors/final control elements are properly maintained.
0
Pressure Regulator Manually adjusted spring-tension device. 1 1 Pressure regulator Manually adjusted spring-tension device. 0
Alarm- Hi/Lo Flow, >10
Manual Response in field > 10 minutes available for Operator
Reponse
1 1
Alarm- Hi/Lo Flow, >40
Manual Response in field > 40 minutes available for Operator
Reponse
2 2
Alarm- Hi/Lo Lev, >10
Manual Response in field > 10 minutes available for Operator
Reponse
1 1
Alarm- Hi/Lo Lev, >40
Manual Response in field > 40 minutes available for Operator
Reponse
2 2
Alarm- Hi/Lo O2, >10
Manual Response in field > 10 minutes available for Operator
Reponse
1 1
Alarm- Hi/Lo O2, >40
Manual Response in field > 40 minutes available for Operator
Reponse
2 2
Alarm- Hi/Lo Press, >10
Manual Response in field > 10 minutes available for Operator
Reponse
1 1
Alarm- Hi/Lo Press, >40
Manual Response in field > 40 minutes available for Operator
Reponse
2 2
Alarm- Hi/Lo Temp, >10
Manual Response in field > 10 minutes available for Operator
Reponse
1 1
Alarm- Hi/Lo Temp, >40
Manual Response in field > 40 minutes available for Operator
Reponse
2 2
Operator response_1
Operator to follow an emergency response procedure under
high stress (life endangering) with less than five minutes to
diagnosis the problem, determine a course of action and
respond.
0 Operator response
Operator to follow an emergency response procedure
under high stress (life endangering) with less than five
minutes to diagnosis the problem, determine a course of
action and respond.
0
Operator response_2
Simple, well-documented action with clear and reliable
indications that the action is required with 10 minute or greater
response time.
1 Operator response
Simple, well-documented action with clear and reliable
indications that the action is required with 10 minute or
greater response time.
-1
Manual operator response in field
> 10 minutes to respond. Provided sensors/alarms are tested
and operator training includes required response.
1 Manual operator response in field
> 10 minutes to respond. Provided sensors/alarms are
tested and operator training includes required response.
-1
Operator response to annunciator
> 10 minutes to respond in the field or > 5 minutes to respond in
the control room. No distractions fromother alarms.
1 Operator response to annunciator
> 10 minutes to respond in the field or > 5 minutes to
respond in the control room. No distractions fromother
alarms.
-1
Operator response to field reading or sample analysis
Time between field readings or sample results is at least twice
the time expected for an initiating event to propagate to the
consequence.
1 1
Operator response to field reading or sample
analysis
Time between field readings or sample results is at least
twice the time expected for an initiating event to propagate
to the consequence.
0
Human double-check
As specified in written procedure, independent work group with
incentives
1 1 Human double-check
As specified in written procedure, independent work group
with incentives
0
Normal operator procedure Simple, well-documented action. 1 1 Normal operator procedure Simple, well-documented action. 0
Instrumented double mechanical seal
As long as the seal measurement includes either regular
monitoring by procedure or an alarmto indicate single seal
failure and a procedure for repair on failure of one seal.
1 1 Instrumented double mechanical seal
As long as the seal measurement includes either regular
monitoring by procedure or an alarmto indicate single seal
failure and a procedure for repair on failure of one seal.
0
Special operator procedure
Failure of a two person checklist procedure (done-by, checked-
by) that has fewer than 10 major steps with a minimumof 40
minutes allowed to detect and correct errors.
1 1 Special operator procedure
Failure of a two person checklist procedure (done-by,
checked-by) that has fewer than 10 major steps with a
minimumof 40 minutes allowed to detect and correct
errors.
0
Deluge System Deluge systemwith auto or manual trip 1 0 Operator Initiated Water Deluge Protection Minimal Fireproofing 1
Flame or Detonation Arrestors - Clean Service
Eliminates the potential for flashback through a piping system
into a vessel, tank or atmosphere. PFD is based on proper
design, installation and maintenance. Clean service.
4 2 Flame or Detonation Arrestors
Eliminates the potential for flashback through a piping
systeminto a vessel, tank or atmosphere.
2
Detonation Arrestors - Dirty Service Fouling or difficult service. 1 Detonation Arrestors Fouling or difficult service. -1
Double Mech Seal Double Mechanical Pump Seals 1 1 Instrumented double mechanical seal
As long as the seal measurement includes either regular
monitoring by procedure or an alarmto indicate single seal
failure and a procedure for repair on failure of one seal.
0
Flame Arrestor Provided maintained routinely 4 1 Flame arrestor Provided maintained routinely 3
HC Detectors Hydrocarbon Detectors with alarm 1 2
Hydrocarbon Detector Initiated Water Deluge
Protection
Minimal Fireproofing -1
Spare pumps Spare pump(s) available 1 1
Seal Drum Water Seal Drum 4 4
Secondary Containment, such as dike, Fire walls (per
PHA)
Design and implementation must be in accordance to applicable
standards. Regular inspection and maintenance is required and
documented.
2 2 Dikes, fire walls, containment, etc.
Design and implementation must be in accordance to
applicable standards. Regular inspection and maintenance
is required and documented.
0
Alarm- Start/Stop
Manual Response in field > 10 minutes available for Operator
Reponse
1 1 Manual operator response in field
> 10 minutes to respond. Provided sensors/alarms are
tested and operator training includes required response.
0
N2 Sweep Multiple Nitrogen Sweeps to Flare 1 1
NG Flow Natural Gas Flow to Flare 1 1
SteamFlow SteamFlow to Flare Stack 1 1
Alarm- Flame Flare Flame/Pilot Indication 1 1
Special PPE Special PPE 1 1 Special PPE -- 0
Fireproofing
Reduces heat input and provides additional time for
depressurizing/fire fighting/etc.
2 2 Fireproofing
Reduces heat input and provides additional time for
depressurizing/fire fighting/etc.
0
Blast-wall/Bunker
Will protect equipment, buildings, and people against
blast/explosion.
3 3 Blast-wall/Bunker
Will protect equipment, buildings, and people against
blast/explosion.
0
Open Vent (no valve) Will prevent overpressure. Clean service 2 3 Open vent (no valve) Will prevent overpressure. -1
Overflow Line No obstructions 3 3 Overflow Line No obstructions 0
CVO Std. IPL Credit Not Available
Mismatch in IPL Credit between CVO &Corp.
Pressure Relief Device with inlet and outlet isolation
valves controlled by administrative procedure
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure & installed
outlet spectacle blind
H
u m
a n I n t e r v e n t i o n
I n s t r u m
e n t a t i o n
Rupture disc
Check valve
Vs. Corporate Std. CVO Std.
Dual Pressure Relief Devices in parallel w/ 3-way valve
or captive key isolation valve
M
e c h a n i c a l D
e v i c e s
3
2
1
Pressure Relief Device Only No isolation valves
Pressure Relief Device with inlet isolation valve
controlled by administrative procedure
Operator Initiated Water Deluge Protection
Monitors Only
F i x e d W
a t e r S p r a y P r o t e c t i o n
CVO Std.
Rupture disc
Flame or Detonation Arrestors
P o s t R e l e a s e P r o t e c t i o n
Open vent (no valve)
H
S E / P o s t R e l e a s e M
i t i g a t i o n
O
p e r a t o r R e s p o n s e
I n s t r u m
e n t a t i o n
M
e c h a n i c a l D
e v i c e
A
d m
i n C o n t r o l s
Hydrocarbon Detector Initiated Water Deluge
Protection
Heat Initiated Water
Shorthand Version of IPL
Mech Integrity
Proc Intervention_2
PSV - Clean Service_4
PVRV - Clean Service_4
PVRV - Dirty Service_4
Alarm - Hi/Lo Flow, >40
Alarm - Hi/Lo Lev, >40
Alarm - Hi/Lo O2, >40
Alarm - Hi/Lo Press, >40
Alarm - Hi/Lo Temp, >40
Spare pumps
Seal Drum
N2 Sweep
NG Flow
Steam Flow
H
S
E
/
P
o
s
t

R
e
l
e
a
s
e

M
i
t
i
g
a
t
i
o
n
A
d
m
i
n

C
o
n
t
r
o
l
s
M
e
c
h
a
n
i
c
a
l

D
e
v
i
c
e
O
p
e
r
a
t
o
r

R
e
s
p
o
n
s
e
CVO Std.
Alarm - Flame
IPL
Number
Shorthand Version of IPL
1 Manual Opertor Response in Field (>24 hr)
1 Operator Response to Annunciator (> 24 hr)
1 Operator Response to Field Reading or Analysis
1 Proc Intervention
1 Chemical Type
1 Low steam pressure alarm
1 Drain Equip
1 Cooling Tower Emissions
1 Operating Procedure
1 Operator Training
1 Vendor QC Program
1 Sample Verification
1 Raw Material Receiving
1 Maintenance Procedure
1 High T/High P Evac Alarm
1 Autorefrig proc
1 Flare Camera
1 Control Valve Mech. Stop
1 CW Exch. Procedure
1 Steam trap
1 Mercury Sieve
1 HRVOC Aanlyzer
1 Engineered controls
1 Engineered design
1 Blind
1 Pipe Upgrade
1 Control Room upgrade
1 Minimum stop
1 Spec Blind
1 Removable Spool
1 Risk Based Inspection
1 RC PSV Inspection
H
S
E
/
P
o
s
t

R
e
l
e
a
s
e

M
i
t
i
g
a
t
i
o
n
1 Confined Space Procedure (inc Safety Disable)
1 Operator Inter.
1 SCV
1 CSN Valve(s)
1 Boiler maintenance
1 Lab Sample
1 Labeling
1 Blind Flange
2 PSV - Clean - BV
2 PSV - Clean - No BV
2 PSV - Dirty - BV
2 PSV - Dirty - No BV
2 PSV/RD Combo
2 Alarm - Composition
2 Ctrl Valve Mechanical Stop
2 CSO Vent
2 PSV + Vent Combination
2 PSV - High N2 Concentration
2 Backup N2 Bottles
3 Alarm - Hi/Lo Flow
3 Alarm - Hi/Lo Lev
3 Alarm - Hi/Lo O2
3 Alarm - Hi/Lo Press
3 Alarm - Hi/Lo Temp
3 BPCS - Auto
3 BPCS - Man
3 Deton Arrest
3 Flame Arrest
3 Stream Analyzer
3 Run Alarm
3 Diked Containment
3 Dry Gas Seal
3 Alarm - Hi/Lo Amps
3 Alarm - Hi/Lo Analyzer
3 CO Detectors
3 Vent Master
3 N2 Pad and Vent
3 Steam Deluge
3 Remote SD Switch
3 N2 Inerting RC/Trucks
3 Breakaway Hoses
3 N2 purge on sumps
3 Gooseneck Vent
3 Secondary Containment
3 Remote S/S
3 Pump Seal Containment
3 Heat Tracing
3 Process Blinds
3 Fire Monitoring
3 Foam Suppression System
3 Alarm-HRVOC Analyzer
3 Manually operated XV
3 Double Isolation Shell Pump
3 Blast Wall/Containment
3 Vapor Equilization
3 Redundant Flare Purges/Nat Gas
3 Liquid N2 System
3 Remote ESD Switch
3 Bullseye
3 Spare blowers
3 Alarm - Flame out
3 Alarm - Hi/Lo Analyzer Conc.
3 Mechanical Governor
3 Alarm - Vibration
3 Alarm - Trouble Alarm
3 Vented Port Valves
3 Alarm- Hi/Lo Vibration Alarm
3 Steam tracing
3 Change in design
3 Motor On/Off
3 Pump Filters/Strainers
3 O2 Analyzers
3 Equipment Design
3 Atmospheric Vent
3 Insulation
3 Spare Column
3 Alarm- Hi/Lo Speed Alarm
3 Freeze protection
3 Double Check Valves
3 Spare Exchanger
3 Mechanical Governor Control
3 Fire Insulation
3 Condensate Removal System
3 Air Valve Surge Drum
3 Alarm - Position Alarm
3 Emergency Team Response
3 Alarm - Material Balance
3 Alarm - Hi/Lo pH Conc.
3 Continuous N2 Sweep
3 Restriction Orifice
3 Frangible Roof
3 Air Scoops
3 Flow Restriction Orifice
3 Fire Monitor
3 Excess Flow Valves
3 Piping Spec
3 Inert atmosphere
3
ESD Interlock
4 M/M Seat Conn
4 Firebox Purge (BMS)
4 Maintain Inert Atmosphere in R-790 vapor space
5 Low Temp
5 High Sodium Nitrite
5 SCV Limit
6 Cut steam to reboiler
6 SCV - Hi/Lo Temp
6 SCV - Hi/Lo Press
6 SCV - Hi/Lo Analys
6 SCV - Hi/Lo Flow
6 SCV - Hi/Lo Vel
6 EBHP Breakthrough
6 R-140/141 Effluent EBHP
6 R-140/141 Off Gas O2
6 T-120 OH Temp
6 T-210/260 Btms Concentration
6 OBVH O2 Concentration
6 Epoxdizer EBHP Breakthrough
6 High EBHP Breakthrough
6 SCV Temp TK-461
7 PM Program
7 Mechanical Inspection
7 ERT Foam
Fire water
8
8 CSO/CSC/Lock Out
8 Analyzer - Acid Strength
8 Low N2 Flow
8 Redundant LM
8 Hydrocarbon monitors
8 Level Meter Alarm
8 XCV
8 PSV
8 Limit stop
8 Vacuum Breaker
8 Line Purge
8 PSV w/ CSO
8 PSV Dirty Serv
8 BPCS Press/ Temp Control
8 Vac Break -Dirty
8 PSV Dirty Service w/ Rupture Disk
8 Hinged Manway as ERV
8 PVSV in clean service
8 Manway PSV with higher pressure set point
8 Vacuum Breaker no block valve
8 BPCS Flow
8 PSV Dirty Service w/ Rupture Disk CSO
8 Double Automated Block valves
8 Pressure Switch - High /Low
8 Pressure Alarm
8 PVSV in dirty service
8 Restricting Orifice
8 Redundant pressure letdown regulator
8 External drum heater
8 PSV Dirty Service with CSO
8 PSV w/ rupture disc w CSO iin clean service
8 Fixed volume fill pot for dual pump seal
8 Continuous visual monitoring-
8 Nitrogen Padding
8 High Level Switch /alarm
8 Overflow Piping
8 Mechanical Integrity inspection plan
8 Redundant power supply
Remarks
CVO
Credit
Corp. Credits
Mechanical Integrity Inspection (must be procedurally driven
- i.e., helogen testing heat exchangers)
1 Leave Blank
Procedural intervention w/ > 40 min available 2 Leave Blank
Relief Device (Inlet and Outlet Isolation Valves) (CSO) 3
3
Based on discussion
with John Remy.
Relief Device (Inlet and Outlet Isolation Valves) 3
3
Based on discussion
with John Remy.
Relief Device (Inlet and Outlet Isolation Valves) 3
2
Based on discussion
with John Remy.
Manual Response in field > 40 minutes available for
Operator Reponse
2 Leave Blank
Manual Response in field > 40 minutes available for
Operator Reponse
2 Leave Blank
Manual Response in field > 40 minutes available for
Operator Reponse
2 Leave Blank
Manual Response in field > 40 minutes available for
Operator Reponse
2 Leave Blank
Manual Response in field > 40 minutes available for
Operator Reponse
2 Leave Blank
Spare pump(s) available 1 Leave Blank
Water Seal Drum 4 Leave Blank
Multiple Nitrogen Sweeps to Flare 1 Leave Blank
Natural Gas Flow to Flare 1 Leave Blank
Steam Flow to Flare Stack 1 Leave Blank
Corp Std. CVO Std.
Flare Flame/Pilot Indication 1 Leave Blank
Remarks
CVO
Credit
Corp. Credits
1 1
1 1
Outside operator field determination of acid strengths
1X(series)/2X(spent) per shift
1 1
Regen procedure 1 Leave Blank
Change Foam type. 1
1
1
1
1 1
Basic Operator Training and HAZCOM 1 1
1
1 1
1
1 1
1
1
1
Minimum flow stop on PIC-3/46004 1
1
1
1
HRVOC flare analyzer 1
Install a packing shield to protect operator from packing
blow out
1
Relocate vent 1
6" blind on line#P46408 1
Install hard pipe 1
Upgrade Control Room 1 1
Mimimum stop of FV-402 1
Steam line is blinded 1
1
Risk Based Inspection Program 1
1
1
1
1
1
1
Daily sample for peroxide and action limit 1
1
1
PSV-12002,PSV-12003, PSV-12004 2 3
PSV-03362 2
4
PSV39009 will protect TK3909 from overpressure 2 2
PSV-34169 2
2
2
DCS Alarm 2
2 1
D-313 CSO Vent to Atmosphere 2
Relief capability through PV-9048 to flare and PSV-97087 2
Case would have high N2 > reduce FL, Ex, EN, and Rx impact
as a result
2
2
Soft Alarm on Low Flow on FIC-03354 3 Leave Blank
LAHL-03200 3 Leave Blank
O2/Comb Analyzers 3 Leave Blank
New High Pressure Alarm and Operator Response 3 Leave Blank
TI-03800A-X or TI-03801A-X or TI-03802A-X 3 Leave Blank
AV-03160 & AE-03160 3 1
Bypass of PSV (to the flare) is always open 3 1
3 4
XFA-28127 3 4
TOC Analyzer 3
YL-17008C / 17009C 3
3 2
3
IAH-57200 3
AIC-57213, AIC57215 3
AT5717, 18, 25 CO Monitors 3
Vent Master on analyzer vents 3 3
3 3
Steam Deluge on reactor seal 3 Leave Blank
HS7046 3
N2 Inerting RC/Trucks 3
Breakaway Hoses w/ isolation valves 3
3
XE-15040 Gooseneck Vent on TK-483 3 3
Diked Area for Tanks/Pump Pad for Pumps & Mixing Station 3
Remote S/S for P-410A/B 3
Seal Guard to Prevent Caustic Spray in Seal Failure Case 3
3 4
3 2
3
3
3
3 0
3
3 3
Vapor equilization with RC during offloading 3 3
3
Backup or redundant N2 system 3
LR or Board operator responds to HC/EO detector HS1300A-
G
3
3
BL-170A/B/C are Spared Blowers 3
Burner Flame Out Alarm
(BS-1501/1502/1601/1602)
3
High T-510 OH MBA Concentration Alarm
(AT-5102MXD)
3
3 1
C-110/160 Common Malfunction Alarm
(ZAHH-1201-1204/1401-1404)
3
Common Trouble Alarm
(AT-1200-1 thru 1200-6)
(AT-1400-1 thru 1400-6)
3
3 3
C-380 High Vibration Alarm
(VA-3670)
3
Steam Tracing 3 1
Balance gas sweep to D-6305 3
M-300 agitator on/off indication
(XL-3105)
3
P-306A/B Filters
(H-3105A/B)
3
3
Equipment Grounding 3
4" Atmospheric (w/Gooseneck) Vent on TK-410 3 3
Thermal insulation 3
T-390 is available at reduced rates 3
C-130/180 Low Speed Alarm
(SI-1201/1401 A/B)
3
Insulation 3
Double Check Valves to Prevent Back Flow 3 2
3
Mechanical Governor is PM'd 3 1
Fire Proof Insulation on the Oxidizer Compartment 5,6 3
Steam Traps on Turbine Inlet 3
Instrument Air Surge Drum Upstream of PSV 3
High OP Alarm on Oxidizer N2 Pressure Control
(HY-1001)
3
Fire Team Responds within 30 Minutes 3
T-120 Material Balance Alarm (Input >> Output) 3
(AI-9009)
Low pH Alarm
3
(FI-9083)
N2 Purge
3
3 2
Frangible Roof 3
TK-60480 Air Scoops 3
FO-6812514 3 2
Fire Monitor 3 0
H - 6812405 3 3
Piping design is to -50 (pipe spec 3CA1P1) 3
N2 pad FI-6812505 3
3
LSH7035
4
4
N2 spargers, vapor space comp. is primarily N2 4
5
5
O2 Concentration 5
6
TI1342/TI1350 6
PI1467/PI1484 6
6
6
6
High EBHP Breakthrough
(AI-3202 and AI-3201)
6
6
6
Safety Critical Variable
(T-120 OH Temperature
< 155F )
6
Safety Critical Variable
(38 wt% EBHP in Bottoms Stream)
6
6
6
High EBHP Breakthrough
(AI-3001 & AI-3002)
6
TI-6019360/361/362 6
7
7
7
Operator/Emgcy Response with Fire Water 1
8
CSO Valve(s) - on 12" and 4" valve 8 1
AI04041 8
8
8
8 3
8
8
8
8
8
8
8
8 2
8
8
8 2
8
8 4
8
8
8
8 2
8
8
8
8 2
8 2
8
8
8
8
8
8
8
8
8 3
8
8
Not Matching with Corp. Std IPL
Not Matching with CVO Std. IPL
IPL Type 1
Team will have to enter this as an "other" IPL
and free text justification.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
Pressure Relief Device with inlet isolation
valve controlled by administrative procedure
& installed outlet spectacle blind.
Pressure Relief Device with inlet isolation
valve controlled by administrative procedure
& installed outlet spectacle blind.
Pressure Relief Device with inlet isolation
valve controlled by administrative procedure
& installed outlet spectacle blind.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
Team will have to enter this as an "other" IPL
and free text justification.
Team will have to enter this as an "other" IPL
and free text justification.
Team will have to enter this as an "other" IPL
and free text justification.
Team will have to enter this as an "other" IPL
and free text justification.
Team will have to enter this as an "other" IPL
and free text justification.
Corp Std.
Team will have to enter this as an "other" IPL
and free text justification.
IPL Type 1
Manual operator response in field
Operator response to annunciator
Operator response to field reading or sample
analysis
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
Normal operator procedure
Manual operator response in field
Operator response to field reading or sample
analysis
Normal operator procedure
Operator response to annunciator
Pressure Relief Device with inlet isolation
valve controlled by administrative procedure
Pressure Relief Device Only No isolation
valves
Pressure Relief Device with inlet isolation
valve controlled by administrative procedure
Pressure Relief Device Only No isolation
valves
Instrumented double mechanical seal
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
The team would have to evaluate if they
actually have 24 hrs to respond to get two
IPL's.
BPCS Automatic control Loop
BPCS - Manual Control Loop
Flame or Detonation Arrestors - Clean Service
Flame or Detonation Arrestors - Clean Service
Dikes, fire walls, containment, etc.
Open Vent (no valve)
Open Vent (no valve)
Steam Flow
Open Vent (no valve)
Dikes, fire walls, containment, etc.
Dikes, fire walls, containment, etc.
Flame arrestor
Restriction orifice
Monitors Only
Manual operator response in field
Blast-wall/Bunker
Open Vent (no valve)
Mechanical over-speed protection
Open Vent (no valve)
Steam Flow
Open Vent (no valve)
Double Check Valve
Mechanical over-speed protection
Restriction orifice
Restriction orifice
Monitors Only
Open Vent (no valve)
Operator Initiated Water Deluge Protection
Car sealing or chain locking manual valve
Hydrocarbon Detector Initiated Water Deluge
Protection
Pressure Relief Device with inlet and outlet
isolation valves controlled by administrative
procedure
Rupture disc
Pressure Relief Device Only No isolation
valves
Rupture disc
Pressure Relief Device Only No isolation
valves
Restriction orifice
Pressure Relief Device Only No isolation
valves
Overflow Line
IPL Type 2
Clean Service. Well designed, fabricated, installed and tested. Testing documented.
Clean Service. Well designed, fabricated, installed and tested. Testing documented.
Dirty Service (dirt, corrosion, polymerizing product, etc.) Well designed, fabricated, installed
and tested. Testing documented.
Corp Std.
IPL Type 2
> 10 minutes to respond. Provided sensors/alarms are tested and operator training includes
required response.
> 10 minutes to respond in the field or > 5 minutes to respond in the control room. No
distractions from other alarms.
Time between field readings or sample results is at least twice the time expected for an
initiating event to propagate to the consequence.
Simple, well-documented action.
> 10 minutes to respond. Provided sensors/alarms are tested and operator training includes
required response.
Time between field readings or sample results is at least twice the time expected for an
initiating event to propagate to the consequence.
Simple, well-documented action.
> 10 minutes to respond in the field or > 5 minutes to respond in the control room. No
distractions from other alarms.
Clean Service. Well designed, fabricated, installed and tested. Testing documented.
Clean Service. Well designed, fabricated, installed and tested. Testing documented.
Dirty Service (dirt, corrosion, polymerizing product, etc.)
Dirty Service (dirt, corrosion, polymerizing product, etc.)
As long as the seal measurement includes either regular monitoring by procedure or an alarm
to indicate single seal failure and a procedure for repair on failure of one seal.
Failure is not an initiating event contributor and sensors/final control elements are properly
maintained.
Greater than 5 minutes available for response. Failure is not an initiating event contributor
and sensors/final control elements are properly maintained.
Eliminates the potential for flashback through a piping system into a vessel, tank or
atmosphere. PFD is based on proper design, installation and maintenance. Clean service.
Eliminates the potential for flashback through a piping system into a vessel, tank or
atmosphere. PFD is based on proper design, installation and maintenance. Clean service.
Design and implementation must be in accordance to applicable standards. Regular
inspection and maintenance is required and documented.
Will prevent overpressure. Clean service
Will prevent overpressure. Clean service
Steam Flow to Flare Stack
Will prevent overpressure. Clean service
Design and implementation must be in accordance to applicable standards. Regular
inspection and maintenance is required and documented.
Design and implementation must be in accordance to applicable standards. Regular
inspection and maintenance is required and documented.
Provided maintained routinely
Clean, non-corrosive, and non-erosive service which will effectively restrict flow to less than
the specified flow-rate under all conditions and upstream pressures.
Fireproofing per company standards
> 10 minutes to respond. Provided sensors/alarms are tested and operator training includes
required response.
Will protect equipment, buildings, and people against blast/explosion.
Will prevent overpressure. Clean service
Tested regularly according to vendor prescription and freq. depending on test results. Testing
documented.
Will prevent overpressure. Clean service
Steam Flow to Flare Stack
Will prevent overpressure. Clean service
Double Check Valve, Scenario related to large backflow only, not leakage.
Tested regularly according to vendor prescription and freq. depending on test results. Testing
documented.
Clean, non-corrosive, and non-erosive service which will effectively restrict flow to less than
the specified flow-rate under all conditions and upstream pressures.
Clean, non-corrosive, and non-erosive service which will effectively restrict flow to less than
the specified flow-rate under all conditions and upstream pressures.
Fireproofing per company standards
Will prevent overpressure. Clean service
Fireproofing per company standards
Car seals or chain locking is only used for scenarios where mis-operation of the valve is the
initiating event.
Fireproofing per company standards
Dirty Service (dirt, corrosion, polymerizing product, etc.)
Difficult application (dirt, corrosion, polymerizing product, etc.)
Clean Service. Well designed, fabricated, installed and tested. Testing documented.
Difficult application (dirt, corrosion, polymerizing product, etc.)
Dirty Service (dirt, corrosion, polymerizing product, etc.)
Clean, non-corrosive, and non-erosive service which will effectively restrict flow to less than
the specified flow-rate under all conditions and upstream pressures.
Dirty Service (dirt, corrosion, polymerizing product, etc.)
No obstructions
Remark Open/Closed
Kept Blank Closed
Kept Blank Closed
Updated Closed
Updated Closed
Updated Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Comments by LYB-Mumbai
Kept Blank Closed
LYB Mumbai Remark Open/Closed
Open
Open
Open
Kept Blank Closed
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Kept Blank Closed
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open
Open