Operating Procedures - hdbk11010035

Exhibit 2.1

DOE-HDBK-1101-96

advised of any necessary changes brought about by the PrHA and may be involved in the design and

implementation of required changes.

Operating Procedures

Employee involvement in the development and implementation of operating, maintenance , and safe

work practice procedures may take several forms.

Consultation during development/implementation to determine if procedures accurately

reflect what is done, what should be done, and the steps necessary to attain the desired result

in a safe and environmentally responsible manner.

Procedure development assignments based on employee knowledge and experience.

Commissioning team assignments to critique and implement new processes or procedures.

Training

Employees may be involved through self-managed learning, coaching new employees, working with

training guides, and one-on-one, on-the-job training in the field. The workplace environment

encourages employees to identify training needs and take part in training development and

implementation.

Pre-startup Safety Review

Whenever possible, cognizant employees will be involved in the performance of the PSR.

Employees are encouraged to have a questioning attitude and report any concerns that are not

addressed by the PSR.

Mechanical Integrity

Maintenance personnel receive training based on written procedures for the maintenance of process

equipment. They must have an understanding of the process and its operation based on applicable

operating procedures, an overview of the process, and process hazards, prior to being qualified.

Employees typically do much of the work in this area--providing input for equipment history and

reliability; recording observed data; maintaining the inspection and maintenance database.

Employees doing the actual test and inspection work are typically asked to review and comment on

manufacturers' recommendations for testing and inspection approaches and frequencies. Employees

take part in equipment failure reviews, participate in work process critiques, and are encouraged to

make recommendations for change.

Hot Work Permit (Nonroutine Work Authorizations)

Employees are involved planning and implementing the safe work procedures documented in hot

work permits and other nonroutine work authorizations.