Background: A decision was taken in the leadership meeting No.152, dated 09.11.2010 and meeting No. 159, dated 12.07.2011 on the process of Work permits system at Drilling Operations based on International Practices. Following are these directives in principle:
To implement Drilling Contractor PTW system in the KOC Drilling Operations.
To validate the Contractors PTW system with respect to KOC PTW System by carrying out Gap Analysis.
If the Contractor PTW system meets or exceeds the Company’s requirements, then contractors may be allowed to use their own PTW system with countersignature of Company representative on PTW Forms
To identify and list the non-routine Critical activities that requires permit to work.
The Task force shall develop a unique PTW process that is specific to Drilling Operations and incorporate relevant clauses in the KOC HSEMS procedure KOC.SA.004 “Permit to Work Procedure” as an appendix in liaison with HSEMS Implementation committee. Such system shall define non routine activities and level of approval.
The drilling area (asset) shall be officially handed over from operations Group to the pertinent Drilling Group for Drilling operational activities through regular KOC permit.
The ‘Appendix – B’ of Permit to Work Procedure is based on the leadership committee directives and PTW IC recommendations focusing on the following issues for Work Permit process at Drilling Rig:
General requirements of Drilling Contractor PTW system
Ownership of Drill Site / Well Site Location
Work Permit process for Drilling Operations.
List of activities of Drilling Contractor that needs PTW
List of PTW activities of Drilling Contractor that need KOC Rig Supervisor counter signature.
Work permit process for Service Contractor Operations at Drilling Rigs
List of Service Contractor activities that require Work permits on Rigs
Categories of work permit & process flow chart
KOC Rig Supervisor/ Company Man Roles & Responsibilities
Tool Pusher/ Night Pusher Roles & Responsibilities
Service Contractor In charge Roles & Responsibilities
Work done on or near drilling rigs by departments other than drilling
Gas Test Requirement at Drilling / Work - over Location
It is to be noted that the purpose of this Appendix ‘B’ is to ensure that the non- routine critical activities which are in the high hazard category as per clause IV & V are carried out by the contractors at the Drilling & Work Over locations with adequate controls for the risk mitigation, by means of a structured PTW Process. The contractor shall bridge the gaps on their PTW procedures with respect to applicable KOC PTW procedure requirements. Accordingly all involved in KOC Drilling & Workover operations must comply with all applicable HSEMS
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Procedures including Appendix ‘B’ of this “Permit to Work Procedure”. The Drilling Contractors may approach their Controlling Team / Group for clarification and assistance on this issue.
I. General Requirements of Drilling Contractor PTW system
The following is the process for review of Drilling Contractor PTW System.
a) All Drilling Contractor working for KOC shall conduct Gap analysis of their PTW system with respect to the KOC HSEMS Procedure on Permit to Work (KOC.SA.004).
b) All the Drilling Contractors shall submit their PTW system along with gap analysis in the template to their respective Superintendent of Contract.
c) Upon receiving the Drilling contractor PTW system along with the Gap analysis, HSE (E&PD) Team will review the PTW system and gap analysis report submitted by Drilling Contractors and prepares a bridging document, which will be forwarded to the Contractor through Superintend of contract for updating their PTW system.
d) The updated drilling Contractor PTW system will be reviewed by HSE E&PD Team.
If the Drilling contractor PTW system meets or exceeds the KOC PTW System requirements including each type of permit then they may be allowed to use their own system with the approval of Supt of Contract, if not the contractor will be further advised to fulfill the KOC requirements. After the initial approval, the contractors PTW system will be reviewed once in every 3 years.
e) Drilling contractors will be advised to update their PTW system clauses periodically based on revision of relevant KOC HSEMS Procedures.
II. Ownership of Drill Site / Well Site Location:
For Drilling and Workover activities; the ownership of well site/ Drilling Area shall be officially released / handed over temporarily to respective teams under Drilling Groups from concerned permanent asset owner (controlling teams under Production Operations, Water handling, Exploration, Gas Development, etc. as applicable) through KOC Permit for Drilling operational activities. The expiry of the permit shall be till the end of completion of well and shall carefully be specified and monitored.
Once handed over to drilling team; the KOC Rig Supervisor/Company Man will be an authorized representative of respective Team Leader of Drilling / Workover Team (Temporary Asset owner) for well operations.
However upon completion of drilling / workover activities, the well site will be handed over /returned to the original asset owner (Operations Group) which is respective Production Operations Team along with permit for closing.
III. Work Permit Process for Drilling & Workover Operations:
The following is process
a) Upon receiving the ownership of the Well site by KOC Rig supervisor, Permit to Spud / workover the well shall be issued by the KOC Rig supervisor to the Drilling Contractor Representative (Tool Pusher) in KOC prescribed format (Attachement-1)for a period till the completion of well. After completion of the well/ job the same permit will be closed prior to rig movement to next location.(Attachment-1)
b) Later all other permits will be issued by Drilling Contractor in their PTW forms for all non-routine and critical activities (identified in this procedure) carried out by rig contractor and service contractor at the rigs.
c) For the Drilling contractor non routine activities requiring PTW, Senior Tool Pusher (STP) / Night Tool Pusher (NP) will issue the Permits and Drilling Contractor personnel will apply for the permit.
d) For the Drilling contractor non routine and critical activities which can affect the well integrity (listed in this appendix B), the PTW form prior to issue will be endorsed
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and counter signed by KOC rig supervisor. In addition, PTW activities which requires overriding of critical safety systems needs to be discussed with operations Team leader (if required TL will discuss with Manager) and upon his approval only the permit can be countersigned by the KOC rig supervisor.
e) For the service contractor activities requiring PTW, rig contractor Tool pusher will issue the PTW and service contractor Engineer / Supervisor will be permit applicant and worksite supervisor. KOC rig supervisor will countersign on the PTW forms issued to service contractors.
f) Permit applicants can apply multiple permits at a time in his area of responsibility but shall not supervise more than one work at a time.
g) Each well location shall have dedicated supervisors and they shall not supervise multiple works / worksites at a time where jobs with PTW are in place.
h) For all permits issued by drilling contractor, a copy shall be submitted to KOC Rig Supervisor.
IV. List of Activities of Drilling Contractor that needs PTW
Activities for which drilling contractor work permits to be issued by senior Tool pusher / Night pusher of the rig.
a) All hot work involving welding, burning, heating, any other spark producing activity generating a potential source, except when done in the approval rig site welding workshop.
b) Isolation/Override/Disabling/Removal of rig safety critical equipment/ systems.
c) High pressure testing of rig equipment such as piping, vessels, well control equipment/manifolds/lines etc.
d) Man-riding & personal basket hoist operations.
e) Use of non-intrinsic electrical equipment in hazardous area at the rig site (cameras / mobiles / radios / portable non-intrinsic gas detection systems etc.)
f) Work on electrical equipment in hazardous areas that can generate sources of ignition.
g) Working on equipment which requires Energy isolation. (Pneumatic & Hydraulic, electrical, spring loaded etc.)
h) Working on equipment which requires Isolation from hazardous substances (hydrocarbon, flammable materials, toxic materials, etc.)
i) Charging of accumulator bottles & pulsation dampeners.
j) Scaffold erection on rig or camp site.
k) All non-routine inspection & maintenance activity on critical rig equipment such as mast, substructure, draw works, rotary, mud pump, BOP control unit, crown block, BOP, top drive, travelling block, load bearing equipment and other fixtures on mast
& substructure during routine rig operations.
l) Commissioning of new machinery during routine rig operations.
m) Installing of third party contractors equipment on the rig (other than drilling contractors)
n) Handling materials weighing more than 85% of SWL of the lifting equipment.
o) All contractor, service contractor & 3rd party vehicle entry to the under hazardous area conditions.
p) Work on / or near moving equipment where safety barriers and guards have to be bypassed / removed.
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q) Working at height (more than 2 meters), except on mud tanks, generator skid, SCR skid, rig floor, monkey board & stabbing board during routine operations.
r) Operations where heavy machinery (e.g. cranes, mechanical excavators, trucks etc.) could pass over live hydrocarbon systems or come into contact with overhead power lines (within approximately 10ft)
s) Use of temporary mobile equipment in hazardous areas (crane, Snorkel Lift, Forklift)
t) Use of portable diesel engines in hazardous area conditions.
u) Any work generating ignition sources inside hazardous area.
v) Operation of permanently installed approved equipment which produced an ignition source or open flame when it operates in hazardous areas.
w) Major work on Xmas tree at rig site while Rig rigging up / down.
x) Work/Entry in the confined spaces where there is a risk from toxic and hydrocarbon fumes or oxygen depletion.
y) Work in contaminated or possibly contaminated atmosphere or in an atmosphere where TLV of a toxic gas is exceeding the acceptable limits.
z) All operations involving X-ray, radioactive & explosives sources.
aa) Working during blow out and serious well control situations.
bb) Transfer of flammable hydrocarbon from trucks (Diesel, OBM etc.).
cc) Rig Move activities
dd) Any other activities which deviate from regular procedures having potential for high risk where JSA alone cannot provide adequate risk mitigation.
V. List of Activities that need KOC Rig Supervisor Endorsement & Counter Signature on the Contractor PTW Form
a) Isolation / removal of safety critical equipment during normal rig operations (emergency power shutdown system, crown saver systems, derrick man’s emergency escape devices, fire pumps, LEL & H2S detection and alarm systems, audio visual alarms at drillers console / BOP control panels, BOP & well control equipment, critical driller console instrumentation systems, Respiratory protective systems (air cascading system, SCBA sets, EEBA sets)
b) All activities mentioned in clause IV of this Appendix-B, when carried out in classified hazardous areas, which has the potential to affect the well condition &
which has the potential to damage well head, X mas tree & valves.
c) High pressure testing and major work on Xmas tree at rig site while Rig rigging up / down.
d) Man riding & personnel basket hoisting operations above monkey board level.
e) Pressure testing of well control equipment when BOP stack is rigging up on well head.
f) All operations involving X-ray, radioactive & explosives sources.
g) Replacement or repair of well head at rig site.
h) Swabbing at night.
i) Working during blow out or serious well control situations.
j) Un-setting packer operations.
k) Welding/Cutting jobs on casing while fitting float shoe and float collar.
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l) High pressure testing of well head and casing.
m) All jobs of service contractors on the rig under clause VII.
VI. Work Permit Process for Service Contractor Operations at Drilling Rigs
a) Permit to Work form of the Drilling Contractor will be used for generating a PTW.
b) Service contractor engineer / supervisor shall be the permit applicant.
c) The permit will be issued by the Drilling contractor senior tool pusher / night tool pusher.
d) For the jobs carried out without the assistance of the rig crew, worksite supervisor shall be the service contractor engineer / supervisor.
e) All simultaneous jobs carried out at the rig by the Drilling contractor and service contractor, the service contractor will be the PTW worksite supervisor. Tool pusher will issue the permit in consultation with Driller / Assistant Driller.
f) The service contractor who applies for permit is also responsible to initiate the process to close the permit as per drilling contractor PTW process
g) Service Contractor shall have the responsibilities of Permit Applicant & Work Site Supervisor & Rig contractor personnel shall have the responsibilities of Permit issuer as per their role in the PTW process in line with KOC PTW procedure & Rig contractor procedures respectively.
h) All the Service Contractor Permits need Rig Supervisor counter signature on the form.
VII. List of Service Contractor activities that require Work permits on Rigs
All the following service contractor activities require PTW and endorsement & counter signature from KOC Rig Supervisor on the permits issued by Tool pusher/ Night pusher
a) High pressure testing of service contractor piping, vessels, BOPs etc.
b) All operations involving X-ray, radioactive, explosives sources.
c) Cementing jobs and associated pumping and pressure testing.
d) Installation and subsequent testing of well heads by service contractors.
e) High pressure stimulation jobs.
f) Coil tubing jobs.
g) Acid jobs h) Well killing jobs i) Swabbing operations.
j) Well testing & flaring
k) Replacement or repair of well head at rig site.
l) Wire line / Slick line jobs at rig.
m) All well surveillance / testing / artificial lift jobs using rigs.
n) Working during blowout & well control situations.
o) All applicable activities involving service contractor when carried out as per activities under Clause No. V of this Appendix-B.
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VIII. Categories of Work Permits & Process Flow chart Tier Description Activities Roles &
Responsibilities
Clause IV Clause X Drilling Contractor representative
KOC Rig supervisor applies for permit to Asset through KOC PTW system. Then the Well site shall be officially released / handed over temporarily to respective teams (Temporary Asset Owners) under Drilling Groups from concerned Assets Teams (Permanente Asset owner) through KOC Permit for Drilling operational activities for the period till completion of Well.
Blanket Permit to Rig move and Spud / work over the well shall be issued by the KOC Rig supervisor to the Drilling Contractor Representative (Tool Pusher) in KOC prescribed format (Attachement-1 of Appendix-B) to issue all permits for a period till the completion of well.
TIER – 1
Drilling contractor non routine activities requiring PTW, senior tool pusher (STP)/night pusher (NP) will issue the Permits and Drilling Contractor personnel will apply for the permit in the Drilling contractor Permit form.
TIER – 2
Drilling contractor non routine and critical activities which can affect the well integrity the Drilling
Service contractor activities requiring PTW, rig contractor Tool pusher will issue the PTW in Drilling Contractor PTW Form and service contractor Engineer/supervisor will be permit applicant and worksite supervisor.
KOC rig supervisor will countersign on the PTW forms issued to service contractors.
After completion of the well/ job, the blanket permit issued at the beginning will be closed prior to rig movement to next location by the Drilling Contractor Representative (Tool Pusher) and KOC Rig supervisor in KOC prescribed format (Attachment-1 of Appendix-B).
Upon completion of drilling / work over activities, the well site will be handed over /returned to the permanent asset owner (Asset Teams) along with KOC permit for closing.
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IX. KOC Rig Supervisor/ Company Man Roles & Responsibilities:
1. KOC Rig Supervisor/ Company man will endorse & counter sign the rig contractor PTW for identified drilling contractor activities’ as listed in clause V under following conditions:
a) Agreeing that the work shall be done by Drilling Contractor personnel on the equipment involved at the proposed time as per the contractor Standard Operating Procedures.
b) Ensure JSA carried out by the rig contractor is attached along with the permit and the hazards identified in the JSA are specific to the job. Ensure pre-job safety meetings are conducted by the rig contractor.
c) KOC rig supervisor may provide additional recommendations as required on necessary worksite preparations and safety precautions.
d) The Drilling contractor personnel has all the responsibilities listed in the Drilling contractors PTW & HSEMS procedures as work site supervisor, permit applicant & permit issuer.
e) All permits will be withdrawn and closed immediately upon any emergency at rig during operations.
2. KOC Rig Supervisor will counter sign the Rig contractor PTW form for service contractor activities listed under clause VII, which is issued by Rig Contractor Tool Pusher/ Night Tool Pusher and applied by Service Contractor at rig site under following conditions:
a) Agreeing that the work done by service contractor personnel who will be responsible & accountable for the work being done on the equipment involved at the proposed time as per the service contractor procedures.
b) Service contractor is responsible & accountable for the identification of all hazards related to their equipment and task and application of risk mitigation measures while generating permit to work.
c) JSA carried out by the service contractor shall be attached along with the permit application with the signature of the service contractor engineer or supervisor.
The hazards identified in the JSA shall be specific to the job.
d) Service contractor is responsible & accountable for the implementation of their HSE MS, JSA & Standard operating procedures for the jobs carried out by them at the rig sites and ensure the PTW process is being carried out in line with KOC PTW procedure (conducting Job risk assessment, JSA, Safety meetings / TBM etc.)
e) Rig contractor STP / NTP & KOC Rig supervisor may provide additional recommendations as required recommending on necessary worksite preparations and safety precautions.
f) All permits will be withdrawn and closed immediately upon any emergency at rig during operational activities.
g) For the purpose of tracking, KOC Rig Supervisor shall maintain a register/
tracking sheet of the permits endorsed by him (for rig contractor & service contractor activities) mentioning the jobs for which the permit, permit endorsement date & time of issue and closure of the permit.
X. Tool Pusher/ Night Tool Pusher Roles & Responsibilities:
1. Tool pusher/ Night Pusher roles and responsibilities while issuing Work Permits in the Drilling Contractor PTW Forms for drilling contractor identified activities’ at rig site are:
a) Shall follow the Work permit process for job activities carried out by rig contractor listed in clause IV as per the process mentioned under clause III of this Appendix-B.
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b) Ensure that the PTW Jobs will be done on the equipment involved at the proposed time as per the contractor Standard Operating Procedures (SOP’s).
c) Responsible & accountable for the identification of all hazards related to the equipment and task and application of risk mitigation measures while generating permit to work.
d) Responsible & accountable for the implementation of their HSEMS procedures for the jobs carried out by Drilling Contractor & sub-contractor at the rig sites as mentioned in clause- IV that requires PTW (job risk assessment, conducting JSA, ensuring relevant Operating procedures are followed for the work, conducting pre job safety meeting etc.)
e) Ensure to implement KOC rig supervisor additional recommendations if any during his counter signature as required on necessary worksite preparations and safety precautions.
f) Has to ensure that responsibilities listed in the Drilling contractors PTW &
HSEMS procedures as worksite supervisor, permit applicant & permit issuer
HSEMS procedures as worksite supervisor, permit applicant & permit issuer