01 BSP-71-Procedure-003 Simultaneous Operations OI - Operating Integrity

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Brunei Shell Petroleum Company Sendirian Berhad

Restricted

BSP-71-P

ROCEDURE

-003

S I M U L T A N E O U S

O P E R A T I O N S

( S I M O P S )

R E Q U I R E M E N T S

F O R

M A N A G I N G

A N D

C O N D U C T I N G

E N G I N E E R I N G ,

M A I N T E N A N C E ,

P A I N T I N G ,

D I V I N G ,

W E L L

E N G I N E E R I N G

A N D

W E L L

S E R V I C E S

O P E R A T I O N S

S I M U L T A N E O U S L Y

W I T H

P R O D U C T I O N

O N

B S P

F A C I L I T I E S

Revision

3.0

Owner: Authors:

BSP-AD Hjh Rosmawatty Hj Abd Mumin HSE/61 Abd-Razak Hj Abu Bakar,

OPM/35 Hazliana Hj Bolhassan

This Revision of BSP-71-Procedure-003

has been updated and extended to also

cover Well Engineering & Well Services

SIMOPS. As such, this document now

effectively supersedes and replaces

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Revision Record

Rev Revision description Date

0 First Issue 1994

1.0 Revision Aug 2000

2.0 Review of document content and rename from CPEMA to SIMOPS March 2009 3.0 Update and extension to cover Well Engineering & Well Services SIMOPS, incorporated

Shell HSSE & SP GCF and DEM-2 requirements, and learning from incidents.

Sept 2012

This document has a maximum validity of five years from the last revision date. Within this period it must be

assessed for relevance and re-validated in accordance with BSP

Document Control Procedure

and Section 6.2

Suggestions for further improvement in this document should be sent to the Document Owner.

Distribution

The document owner is responsible for distribution control. The original electronic version is stored in

LiveLink and accessible via BSP OnLine web site. Paper copies are only controlled if they are physically

stamped “Controlled Hard Copy” , signed by the related remote location document controller and recorded in

the BSP71 Master Inventory.

Notice and Warning

Copyright



2012, Brunei Shell Petroleum Company Sendirian Berhad

This document is the property of Brunei Shell Petroleum Company Sendirian Berhad (BSP), Seria KB3534,

Negara Brunei Darussalam. Circulation is restricted to BSP and its designated associates, contractors and

consultants. It must not be copied or used for any other purpose other than that for which it is supplied,

without the express written authority of BSP.

Except where provided for purposes of contractual requirements, BSP disclaims any responsibility or liability

for any use or misuse of the document by any person and makes no warranty as to the accuracy or suitability of

the information to any third party. Any misuse of the document is redressable by BSP.

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_Inspection

... 47

5.12 Hot Work ... 48

5.12.1 General Requirements ... 48

5.12.2 PTW Restrictions for Hot Work in Hazardous Areas ... 48

5.12.3 Hot Work Preparations ... 49

5.12.4 Gas Testing ... 50

5.13 Surface Preparation, Cleaning, Painting and Coating or Lining ... 50

5.13.1 High Pressure Water Jetting ... 51

5.13.2 Blasting ... 51

5.13.3 PTW Restrictions for Surface Preparation, Cleaning and Painting ... 52

5.14 Underwater Activities ... 54

5.15 Shift Changes During SIMOPS Programs ... 54

5.16 Emergency Response ... 54

5.16.1 On Scene Commander (OSC) ... 54

5.16.2 Emergency Escape ... 55

5.16.3 Emergency Response Drill ... 55

6 MANAGEMENT REVIEW ... 56

6.1 After Action Reviews ... 56

6.2 BSP71-Procedure-003 SIMOPS Process Manual Updates ... 56

6.3 Audits of CSHC‟s and PHP‟s ... 56

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8 APPENDICES ... 59

Appendix 1 – Generic SIMOPS Task list ... 60

Appendix 2 – SIMOPS Initiation Approval Form ... 62

Appendix 3 – SIMOPS Change Proposal Form... 63

Appendix 4 – PHP Cover page, Signatory page & Suggested Table of Contents ... 64

Appendix 5 – Structure and Contents of a Campaign-Specific SIMOPS HSE Case (CSHC) ... 67

Appendix 6 – Process Safety Basic Requirements - Brief Reference ... 68

Appendix 7 – Pre-SIMOPS Facility Inspection Checklist ... 70

Appendix 8 – Confirmation of Integrity Memos ... 74

Appendix 9 – Host Facility Hand Over Checklist ... 77

Appendix 10 – Host Facility Hand-back Checklist ... 82

Appendix 11 – Example of a Standard Habitat Used to contain welding hot work slag / sparks (ignition sources) ... 85

Appendix 12 – RASCI MATRIX for Offshore Campaign Process ... 86

Appendix 13 – RASCI MATRIX For Offshore/Onshore Blasting & Painting Campaign Process ... 87

TABLES Table 1. Generic SIMOPS Process Phases, Activities & Responsible Parties... 9

Table 2. Process Flow for a typical Engineering / Maintenance SIMOPS Program or Campaign ... 9

Table 3. Process Flow for a Typical Drilling or Well intervention SIMOPS Program or Campaign... 10

Table 4. Definitions ... 11

Table 5. SIMOPS Process Forum Responsibilities ... 14

Table 6. Asset Unit Responsibilities ... 15

Table 7. Typical Lead Time for Stage 1 of SIMOPS Planning... 18

Table 10. Special Issues For SIMOPS At Normally-Manned Facilities ... 28

Table 11. Pre-SIMOPS Inspection Checks ... 33

Table 12. Well Equipment Checks ... 34

Table 13. Default Platform Shutdown and Depressurisation Requirements for Final Move-in and Positioning ... 41

Table 14. Facilities Hand-Over Default Rules ... 42

Table 15. Default Platform Shutdown and Depressurisation Requirements for Helideck Lifts and Rig-Up/Down involving Heavy Lifts ... 44

Table 16. Default Platform Shutdown and Depressurisation Requirements for Other (Heavy) Lifts and Equipment Moves ... 44

Table 17. PTW Restrictions for Hot Work in HAC zones ... 48

Table 18. Summary Of Restrictions On Blast Cleaning In HAC Zones ... 53

FIGURES Figure 1 SIMOPS Justification Balance ... 16

Figure 2 Group Risk Assessment Matrix (RAM), Version 2, December 2009 ... 21

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1 I

N T R O D U C T I O N

1.1 Purpose and Document Structure

The purpose of this BSP generic SIMOPS procedure, also known as the „SIMOPS Process Manual‟, is to define BSP requirements to be applied in order to safely manage multiple activities being performed simultaneously at a location, particularly when one of those activities is the production of Hydrocarbons. This is referred to as “simultaneous operations”, or “SIMOPS”.

The purpose of undertaking activities as SIMOPS is to reduce production deferment, while maintaining risks at a level that is ALARP.

Sections 1 to 3 of this document describe the management process and management requirements for SIMOPS on BSP facilities. They include a description of the steps involved in SIMOPS programs, key roles & responsibilities of parties involved in SIMOPS and mandatory requirements for initiation & planning of SIMOPS programs.

Sections 4 and 5 of this document address requirements for site/platform preparation for SIMOPS and execution of SIMOPS programs.

Section 6 covers Management Review activities, as required to ensure continuous improvement.

1.2 Scope

The scope of this SIMOPS Process Manual includes:

 Well Engineering & Well Services Activities on live BSP production facilities, onshore and offshore, including:

o Drilling and other Drilling Rig supported activities i.e. „CPRA‟ o Well Intervention Unit (WIU) and Hoist activities

o Coiled Tubing Unit (CTU) activities o Wireline and Slickline activities.

 Engineering / construction, maintenance and commissioning activities on live BSP production facilities, onshore and offshore, i.e. „CPEMA‟

 Painting activities on live BSP production facilities, onshore and offshore, i.e. „CPPA‟  Underwater (Diving) activities at live offshore BSP production facilities.

Note that the safety management requirements for each of the above differ.

If a small team of personnel are put onto a live facility to do some minor engineering or maintenance, is this SIMOPS?

Providing that the host facility SCE, including ETRER systems, and HSE Case remain valid and applicable for these personnel + their activities, and the POB limit for the facility is not exceeded, and the personnel are not going to interfere with any of the SCE, nor do any category 1 hotwork, then the answer is „No, this is not SIMOPS‟

If a workboat is to be sent to a live NUI and a team of 30 personnel are going onboard to do some engineering or maintenance that does not involve category 1 hotwork, is this SIMOPS?

Yes, even though they will not be doing hot work, this is SIMOPS because the workboat constitutes an additional MAH, and the NUI ETRER systems are not designed for 30 people and this correspondingly exceeds the maximum POB.

A Wireline Unit and Team are to be sent to a live Drilling Platform to do some well servicing work on closed-in wells: does this constitute SIMOPS?

Yes, this is SIMOPS Well Services Activities on live BSP production facilities are specifically included in the scope of this SIMOPS Process document.

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1.2.1 Well Engineering & Well Services Activities

Typical Well Engineering & Well Services activities within the scope of this manual include: i. Well Engineering Activities (on a live production facility):

 Drilling rig and WIU Barge movements and rig-up/rig-down1  Workover of existing wells

 Drilling and Completion of new wells (including component activities such as milling, cementing, fishing, coring etc.).

The following activities may also be carried out as part of the above, either as on-line second activities or as off-line third activities2:

o Perforating

o Stimulation (Acidising) o Fracturing

o Well kick-off (including use of N2) o Logging

o Securing (well killing)

o CTU and Wireline/Slickline operations while the Rig or WIU is present o Conductor driving

o Grouting.

ii. Well Services activities (on a live production facility):

 Well Intervention Unit (WIU) or Hoist-Assisted Well Service Operations involving well workover and completion where there is a need to carry out pulling and installation of tubing for the production string

 Coiled Tubing Unit (CTU) or Wireline Unit Well Service Operations, not requiring a drilling rig or WIU e.g. Surface-Controlled Subsurface Safety Valve (SCSSSV) change-out, gas lift valve change-out, plugging, bottom hole pressure survey, tubing calliper survey, debris removal, wax cutting, etc.

1.2.2 Construction Activities

Typical Construction activities (on a live production facility) within the scope of this manual include:  Work barge/boat movements

 Spading and De-spading

 Heavy lifts, difficult lifts and material handling  Rigging and scaffolding

 Pile driving, pipe laying, and riser installation  Pigging, flushing, and purging

 Welding, grinding, gas cutting  Hydrotest

 Grit/hydro blasting and spray painting  Laying cables and tubing

 Installation of electrical and instrument systems  Platform Cleaning.

1.2.3 Commissioning Activities

Commissioning is the functional and performance testing of equipment and systems to ensure compliance with design specifications before handing over the equipment and/or facility to Operations. Typical

1

The platform will not normally be live for these activities, but they still form part of the overall Well Engineering SIMOPS program

2

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equipment and systems that could be the subject of commissioning activities (on a live production facility) that fall within the scope of this manual include:

 Mechanical equipment, and associated vessels and systems  Electrical installations and instrument systems

 Safety and fire fighting systems.

1.2.4 Maintenance Activities

Maintenance work is categorised as either:

a. Topsides Maintenance (onshore and/or offshore)

b. Underwater Maintenance (including Diving Activities - offshore). 1.2.4.1 Topsides Maintenance (on a live production facility)

Typical Topsides Maintenance activities within the scope of this manual include:  Work barge/boat movements

 Lifting and materials handling  Demolition work

 Rigging and scaffolding  Welding, grinding, gas cutting

 Hydrotest and functional testing of facilities  Grit/hydro blasting and spray painting  Re-laying cables and tubing

 Work on electrical and instrument systems  Platform cleaning

 Onsite Inspection

 Vessel inspection/cleaning  Relief valves change out.

1.2.4.2 Underwater Maintenance (at a live production facility)

Underwater Maintenance (at a live production facility) is defined as any maintenance, construction or other support work carried out in the splash zone or below Mean Sea Level (MSL) - down to the seabed on or in the vicinity of the installation, including subsea pipelines. Typical Underwater Maintenance activities within the scope of this manual include:

 Diving Support Vessel movements

 Structural and pipeline/riser inspections, both detailed and general  Repair of structures and pipelines / risers

 Well conductor inspection  Damage survey

 Debris survey and recovery  Pipeline survey

 Anode replacement  Single buoy mooring

o Underwater hose inspection including replacement o Buoy inspection and change-out.

1.2.5 Painting Activities

First aid painting does not fall within the scope of SIMOPS. However painting campaigns involving grit/shot blasting, large crews and/or use of a dedicated workboat / painting boat at a live production facility do fall within the scope of this document.

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1.2.6 Diving Activities

Diving Activities (more correctly termed “Underwater Activities”) are required for Underwater Maintenance (see above) and for some construction activities (e.g. installation of riser clamps for new pipelines) and to support some well engineering activities (e.g. use of an ROV to monitor JU spud can positions relative to pipelines). When these activities are conducted at live production facilities or simultaneously with other campaign activities (at the same offshore facility), they constitute SIMOPS and thus fall within the scope of this document. However, diving activities require highly specialist controls, most of which are not defined in this generic SIMOPS document – reference must therefore be made to the relevant elements of BSP HSE management system documentation and the relevant BSP service unit (AEO/4) for full details of management controls for Diving SIMOPS.

1.3 SIMOPS Process Overview

Every SIMOPS program consists of three distinct phases – the initiation, planning and execution phases – each with single point accountability and distinct hand off points. Overall accountability for each SIMOPS program is with the Asset Manager for the facility where the SIMOPS will take place.

The following three tables illustrate the process flow for typical generic SIMOPS Programs. Reference may also be made to the Generic SIMOPS Task list in Appendix

1

.

Table 1. GENERIC SIMOPSPROCESS PHASES,ACTIVITIES &RESPONSIBLE PARTIES

Phase Accountable Party Activities & Responsible Parties

Initiation Asset Maintenance Support Engineer (AE)

- or -

Well Activity Owner (XPE/3x)

Well Activity Owner (WAO) or Project Leader (PL) prepares an initial risk assessment and justification for completing the work as a SIMOPS program. On receipt of endorsement from the Asset Maintenance Support Engineer or Head Petroleum Engineer (XPE – in the case of well engineering and well services), the proposal is tabled at the Medium Term Integrated Activity Planning (IAP) Forum for consideration and inclusion in the “RAP”. Once the program has been included in the RAP, it is submitted to the Asset Manager for formal approval.

Provided that the Asset Manager approves the program, it progresses to the planning phase Planning SIMOPS

Coordinator Production Support or Campaign Manager

The SIMOPS Coordinator will organise a campaign / program specific HAZID and oversee the preparation of a Campaign-Specific HSE Case (CSHC) or Project HSE Plan (PHP) (as applicable) for the program, with the AO or PL remaining the responsible party for detailing the work pack and the incorporation of the appropriate controls. During this phase, the SIMOPS Coordinator ensures facility integrity checks, inspections and verifications required for the program are all carried out. The CSHC or PHP includes all the requirements and campaign / project scope in a single document and serves as the prime means of communicating these requirements to all people involved in the execution of the program.

Provided that the Campaign HSE Case or Project HSE Plan (as applicable) has been approved, the project enters the execution phase

Execution Person-in-Charge PIC i.e. OIM / DSV / PL

Resources are mobilised to site, installed systems and ER preparedness are tested / verified, and the program is executed in accordance with the plan.

Carry out After Action Review (AAR) to ensure that major highlights of the program are noted and used to improve the process

Table 2. PROCESS FLOW FOR A TYPICAL ENGINEERING /MAINTENANCE SIMOPSPROGRAM OR CAMPAIGN

Phase Task Milestone Guide*

Initiation 1 Compile initial scopes provided by Asset (Campaign booklet) and prepare proposal for SIMOPS (SAP, CIRRAS, Project, Asset Maintenance Plan, etc.

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Phase Task Milestone Guide*

2 Initial HAZID / Risk Assessment for SIMOPS

3 Request include/change in Short Term 90 days activity plan change control

4 Obtain Asset Manager approval for SIMOPS

Planning 5 Finalise SIMOPS Scopes

6 Confirm risk assessment on site and conduct bow tie gap analysis 7 Conduct IPOP and any other additional HEMP studies

8 Issue workpack/job cards & construction spading list for approval -16 weeks

9 Freeze SIMOPS actual workpack -4 weeks

10 Close out HAZID & IPOP actions -4 weeks

11 SIMOPS PHP / CSHC Approval -4 weeks

12 Final pre-SIMOPS inspection and onsite communication -4 weeks

Execution 12 Carry out SIMOPS

13 Post-SIMOPS verifications before production start up

END 14 Conduct After Action Review (AAR) +1 week

* Negative numbers denote time prior to commencement of SIMOPS. Bold font denotes mandatory milestone timing

Table 3. PROCESS FLOW FOR A TYPICAL DRILLING OR WELL INTERVENTION SIMOPSPROGRAM OR CAMPAIGN

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1.3.1 RASCI Charts

RASCI Charts have been created to indicate who is responsible, who is accountable, who needs to provide support, who needs to be consulted and who needs to be informed at each stage of typical SIMOPS campaigns. These are presented in:

 Appendix 12 for Typical Engineering / Maintenance SIMOPS Campaign RASCI  Appendix 13 for Typical Blasting and Painting SIMOPS Campaign RASCI Relevant definitions are provided overpage.

LEGEND FOR RASCI

R- Responsible

Responsible to do it or get it done: the executing party. The Responsible party executes the necessary work and takes the actions required to ensure compliance with legal requirements and BSP Policies and Standards

A – Accountable

Accountable approves, must “sign off” acceptance of results. The Accountable party approves the work done by the Responsible party and is Accountable for the results

S – Support

Support to the Responsible party and the Accountable party

C – Consulted

Shall be consulted by the Responsible party on activities and results. The Consulted party must be given an opportunity to contribute

I – Informed

Shall be informed about decisions, activities and results.

1.4 Terminology

Abbreviations, terms and references used frequently in this and other management system documentation are defined in the Management System Glossary. Terminology specific to this document is given in the table below.

Table 4. DEFINITIONS Abbreviation/Term Meaning

AAR After Action Review

Accountable Accountable approves, must „sign off‟ acceptance of results. The accountable party approves the work done by the Responsible Party and is Accountable for the results Accountable person The person with the authority to approve or disapprove a proposal made by the individual

responsible. Without this approval the implementation of any proposal will not proceed. It is a de facto right to veto a proposal.

AE Asset (Maintenance Support) Engineer AED Asset Engineering Design (BSP department)

AEN Engineering & Construction Onshore (BSP department) AEO Engineering & Construction Offshore (BSP department) AFC Approved For Construction

Aka also known as

ALARP As Low As Reasonable Practicable. A level of risk where the time, difficulty and cost of further risk reduction become unreasonably disproportionate to the risk reduction obtained.

AM Asset Manager

Anomaly A defect, resulting from corrosion or erosion, detected on process piping, risers, vessels or structures.

AO Activity Owner e.g. AEO, TSW (see also „WAO‟)

AU Asset Unit

BFD Basis For Design

BTA Bow Tie Analysis

Consulted Shall be consulted by the Responsible party on activities and results. The Consulted Party must be given an opportunity to contribute

CPRA Concurrent Production and Rig Activities (i.e. Well Engineering SIMOPS) CPEMA Concurrent Production, Engineering and Maintenance Activities (SIMOPS) CPPA Concurrent Production and Painting Activities (SIMOPS)

CSHC Campaign-Specific (SIMOPS) HSE Case (see Section 3.2.9.2) CSR Company Site Representative

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Abbreviation/Term Meaning

CTU Coiled Tubing Unit

DFPV Depressurising – Flushing – Purging – Venting

DP Drilling Platform

DSV Drilling Supervisor

EC Emergency Coordinator

ECT Emergency Coordinator Team

EERA Escape Evacuation & Rescue Assessment EFA Emergency Facilities Assessment

EPA Shell Exploration and Production Asia Pacific

ER Emergency Response

ESSA Emergency System Survivability Analysis

ESD Emergency Shutdown

ESDV Emergency Shutdown Valve

ETRER Escape, Temporary Refuge, Evacuation and Rescue EWIMS Electronic Well Integrity Management System F&G Fire & Gas (detection)

FOG Falling Objects Guide

FRED Fire, Release, Explosion and Dispersion modelling software GSS General Shift Supervisor

HAC / HACC Hazardous Area Classification / Hazardous Area Classification Committee (see „Zone‟ definitions below)

Hand-over The transfer of custody from one department to another department. This is considered a temporary change of ownership of the platform.

HAZAN Hazard Analysis, including phenomenological modelling such as FRED hazard range assessments

HAZID Hazard identification exercise. A “desk-top” evaluation exercise carried out to identify and document all hazards associated with a particular activity

HC Hydro Carbons

HEMP Hazards and Effects Management Process

HiPo High Potential (used in reference to any incident with high potential for a serious accident) HSE Health, Safety and Environment

IA Instrument Air

IAP Integrated Activity Plan

IG Instrument Gas

IFA Issued For Approval

Informed Informed. Shall be informed about decisions, activities and results IPOP Integrated Planning On Paper

JHA Job Hazard Analysis

JU Jack-Up

LFL Lower Flammability Limit i.e. the minimum concentration of a flammable gas in air for the mixture to be flammable (same as LEL - Lower Explosive Limit)

LIPPs Lightweight Impact Protection Plates

LOC Loss of Containment

MAH Major Accident Hazard i.e. a credible accident hazard with risk that is potentially in the Red or Severity level 5 areas of the Group RAM

MAHAS Major Accident Hazard Assessment Sheets

Manned Facility A facility that has people permanently located on it and has permanent living quarters

MAT Major Accident Threat

MODU Mobile Offshore Drilling Unit MOPO Manual Of Permitted Operations MPM Major Projects (Department of BSP) MPFM Multi-Phase Flow Meter

MSL Mean Sea Level

NPT Non Productive Time

NUI Normally Unmanned Installation OIM Operations Installation Manager

OM Operations Manager i.e. Head of Operation (XOPs)

OSC On Scene Commander

PA Public Announcement

PAR Piping Anomaly Report

PEC Plan Entry Criteria

PEP Project Execution Plan PEM Physical Effects Modelling

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Abbreviation/Term Meaning

PHP Project HSE Plan (see Section 3.2.9.1)

PIC Person In Charge

PIP Permit In Place

PL Project Leader

POB Personnel On Board

PM Preventative Maintenance

Production Activities Activities related to producing of hydrocarbons i.e., “live” facilities. PSBR Process Safety Basic Requirements

PTB Personnel Transfer Bridge (aka Gangway)

PTW Permit To Work

QRA Quantitative Risk Assessment

RAM Risk Assessment Matrix

RAP Rolling Activity Plan

RASCI Responsible, Accountable, Support, Consult, Inform. ROV Remotely Operated Vehicle

SAR Structure Anomaly Report

SC SIMOPS Coordinator (aka „CPRA Focal Point‟ in the case of well engineering SIMOPS) SCE Safety Critical Element

SCSSSV Surface-Controlled Subsurface Safety Valve

SIMOPS “Simultaneous Operations” is defined as multiple work activities taking place at the same time, at the same location. This typically includes the following combinations:-

 Maintenance/improvement/Diving/Painting activities with production activities  Engineering/construction or commissioning activities with production activities  Drilling and Well Services with production activities

SOS Senior Offshore Supervisor

SRI Safety Related Item

SSOW Safe System Of Work

SSV Surface safety valves

SU Service Unit

TA Technical Authority

TR Temporary Refuge

TRIA Temporary Refuge Impairment Assessment

Unmanned facility A facility that does not have people permanently located on it, although it may be visited regularly.

WAO Well Activity Owner

WIU Well Intervention Unit

WJ Well Jacket

WS Work Supervisor

Zone 0 An area is which a hazardous atmosphere is continuously present.

Zone 0 classification applies to the internals of process vessels, storage tanks and other similar closed containers. Any source of ignition in a Zone 0 area would, almost certainly, lead to a fire or explosion.

Zone 1 An area in which a hazardous atmosphere is likely to occur during normal operating conditions.

Zone 1 classification applies in production areas around process vessels, wellheads, open drains, vents etc. and in all areas where gas is used as the drive material for instruments.

Zone 2 An area in which a hazardous atmosphere is not likely to occur during normal operations and, if it does occur will exist only for a short period.

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2 R

E S P O N S I B I L I T I E S

This section builds on the RASCI defined in Section 1.3 above, by further defining major responsibilities associated with SIMOPS management. Also, to aid in completing tasks, the key players can refer to the Generic SIMOPS Task Checklist in Appendix

1

.

Each SIMOPS program shall have a dedicated resource to coordinate the program including its required HEMP studies. This is an HSE-Critical role and as such, the candidate shall have been assured as competent as appropriate for the scope of the program, before taking on the role.

2.1 SIMOPS Process Forum Responsibilities

The overall responsibilities for SIMOPS are divided between the “SIMOPS process forum” and the Asset Units. The “SIMOPS process forum” is responsible for the “SIMOPS process”. The responsibilities are listed in Table 5 below.

Table 5. SIMOPSPROCESS FORUM RESPONSIBILITIES

Category Description

Generic SIMOPS HSE Case

Ensure the BSP generic („Base‟) SIMOPS HSE Case and the template for campaign-specific HSE Cases are reviewed and updated in line with corporate standards. Ensure the documents are transferred to the Asset Units for implementation.

Campaign-specific SIMOPS HSE cases & Project HSE Plans

Ensure that the appropriate Asset Unit prepares a campaign-specific SIMOPS HSE Case (CSHC), or Project HSE Plan (PHP), as appropriate – reference Section 3.2.9.

Process management manual

Act as custodian of the SIMOPS Process Management Manual (this document). Update the manual as necessary to ensure that it complies with latest Group standards, includes learning from latest industry experience and incidents, and remains compatible with the latest revision of the SIMOPS Base HSE Case.

Engineering Ensure that all engineering designs in the SIMOPS program (including well engineering) comply with the relevant corporate engineering standards. Refer specialist questions to the relevant engineering departments and advise the Asset Unit on the technical issues, limits and requirements of the engineering works.

Campaign Services, Well Services, Painting Services

Develop the detailed work packs, approve and implement the Services campaign sequence. Advise the Asset Unit on technical issues, limits and requirements of the Services campaign sequence.

Training Identify any specific training requirements for the SIMOPS and ensure that all personnel involved in executing the SIMOPS are competent in their responsibilities.

Review Ensure that learning from each SIMOPS Program is identified and used to achieve continuous improvement in SIMOPS risk management.

Transfer of information

Ensure that each Asset Unit uses a consistent approach to SIMOPS. Ensure that relevant information and practices are transferred between Asset Units.

2.2 Activity Owner (AO) Responsibilities

The AO i.e. Engineering & Construction Planner (AEO/AEN), Major Project Leader (MPM/xx) and/or Production Technologist (XPE/3), has responsibilities in all three phases of a SIMOPS program, including:

 Initiation phase:

o Preparing a brief justification for why the work should be done simultaneously o Doing an initial risk assessment (using the Group RAM – see 3.2.1 below)

o Tabling the SIMOPS proposal to the 2 years Medium Term RAP Forum, or the appropriate IAP forum, for inclusion in the RAP

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 Planning and Execution phases: o Detailing the work packs

o Providing competent Supervisors for all activities

o Executing the work in accordance with the CSHC or PHP.

The AO conducts AAR‟s. With the AO‟s involvement in this task, the feedback loop is complete, as the AO has an oversight role across the phases of the program and learning can be incorporated into impending SIMOPS programs. It is left to the discretion of the AO, to complete the AAR on an individual basis, or to cluster and complete them in groups.

2.3 Asset Unit Responsibilities

The Asset Units have responsibilities in all three phases of a SIMOPS program, including those listed in Table 6 below.

Table 6. ASSET UNIT RESPONSIBILITIES

Category Description Responsibility

HSE  Initiate, and assist with collection of information for, a hazard identification (HAZID) and ALARP Assessment study, any other HEMP Studies (e.g. QRA) needed to ensure that all significant risks will be identified and demonstrably reduced to ALARP for each SIMOPS program.

 Follow through recommendations from the HAZID and ALARP Assessment exercise and any other HEMP studies undertaken for the proposed SIMOPS, to ensure they are closed out as appropriate.

 Provide the risk inputs to the justification for each SIMOPS program (see “Economic assessment” below).

 Contribute to SIMOPS plans to ensure that the risks of carrying out SIMOPS will be ALARP.

 Initiate, and support as necessary, the preparation of a campaign-specific SIMOPS HSE Case (CSHC), or Project HSE Plan (PHP), as appropriate for each SIMOPS program – reference Section 3.2.9.

 Ensure integrity checks, remedial actions and “fit for purpose” verifications are completed in accordance with the CSHC / PHP.

 Ensure any late changes are reviewed by the HAZID team before approval.  Organise formal approval of the CSHC / PHP after all supporting information

is in place.

XOP/1 XOP/5

Operations  Carry out the day-to-day planning and implementation of SIMOPS programs.  Compile production deferment information, with input from Development,

Business Support, Technical Services Well Engineering and Operations Programming.

 Ensure the SIMOPS programs are included in the “Rolling Activity Plan” (RAP) and “90 Day Plan”.

 Determine production facility limits, the planning of shut downs and deferment.

XOP/1

Engineering  Initiate the inspection of the host facility hydrocarbon containment systems, structure and safety systems.

 Initiate surveys, as appropriate of the SIMOPS site/area (e.g. seabed debris survey, soil boring survey).

 Obtain an estimate of the cost of the SIMOPS program.

XOP/1

Economic assessment

 Provide the economic justification for each SIMOPS program clearly showing that the production benefit from conducting the work as SIMOPS outweighs the incremental risk relative to conducting the work in shutdown mode.

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Category Description Responsibility

Review  Carry out review of each SIMOPS after it is completed and identify learning points for incorporation in future programs and the Process Manual and/or Base HSE case.

XOP/1 XOP/5

Training  Ensure that all Operations Representatives and other production staff are competent in their SIMOPS responsibilities.

XOP/1

2.3.1 Asset Manager (AM)

In the initiation phase, the AM is accountable for the approval of the SIMOPS. In order to approve the SIMOPS, the AM must be satisfied that:

1. HSE risks associated with the SIMOPS are, and will continue to be throughout the program, tolerable and ALARP, in full compliance with BSP and Shell Group requirements (Refs. 6, 16) 2. The cost of the risk mitigation measures required to achieve (1) is balanced by the saving in

deferment cost by not shutting down.

3. Any late changes to the SIMOPS program have been managed and approved through the Change Control Procedure described in Section 3.3.

Figure 1. SIMOPS Justification Balance

2.3.2 Asset Engineer (AE)

The Asset Engineer (AE, XOP/2) provides oversight on behalf of the Asset Manager regarding the SIMOPS proposal. In carrying out this task, the AE will seek endorsement from the Activity Manager, without whose endorsement, the proposal cannot move forward to the Medium Term RAP Forum.

2.3.3 AU CPRA / SIMOPS Coordinator (SC)

The Asset Unit Production Support Engineer acting as SIMOPS Coordinator (SC, also known as the „CPRA Focal Point‟ in the case of well engineering SIMOPS) has a central role in SIMOPS management, and carries the single point accountability during the planning phase, reporting directly to the AU Operations Manager, to ensure that:

 All activities and requirements are integrated into the program

 Facility integrity checks, inspections and verifications as required for the program are carried out

 HEMP study requirements are identified and carried out, such that major accident hazards, threats, and critical risk controls are known and catered for in the program

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 A quality CSHC or PHP (as appropriate to the nature of the SIMOPS) is prepared, detailing required preparatory / remedial work and key risk controls and responsibilities

 SIMOPS planning & preparation milestones are monitored and the Asset Manager is alerted if any milestone dates are missed, so the AM can make a decision regarding continuing with the plan for SIMOPS.

2.3.4 Person-In-Charge (PIC)

The Person-In-Charge (PIC) at the SIMOPS site i.e. the OIM, CSR or DSV, has responsibilities in the Planning and Execution phases, as follows:

 In the planning phase, the PIC provides support to the SC as necessary for obtaining approval of the SIMOPS plan

 In the execution phase the PIC will have single point accountability for safe execution of activities, well-being of personnel, assets and the environment in accordance with the CSHC / PHP. This requires on-site coordination of activities, setting priorities and making on-site evaluations of the consequences of concurrent activities upon each other (taking due account of the prevailing MOPO).

2.4 Rolling Activity Planning (RAP) Forum

The RAP Forum provides an integrated review of the SIMOPS proposal, with the Forum‟s key responsibility being implementation of the IAP planning process including assessment of Plan Entry Criteria (PEC) for inclusion in the 2 years look-ahead plan.

2.5 SIMOPS Process Manual Custodian

Annual SIMOPS Reviews shall be carried out by the SIMOPS Process Manual Custodian i.e. HSE/61 to ensure that:

 A consistent approach is used for all SIMOPS programs

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3 I

N I T I A T I O N

&

P

L A N N I N G O F

S I M O P S

P

R O G R A M S

3.1 Planning Milestones

The SIMOPS process includes a set number of planning „milestones‟. These are as listed in Table 2: there are three fixed milestones to be completed before start of the Execution Phase work onsite:

 Work pack issue for approval (16 weeks before SIMOPS commencement)  Approval of the CSHC or PHP (4 weeks before SIMOPS commencement)  Final pre-SIMOPS inspection (4 weeks before SIMOPS commencement). The time frames for the other milestones are contingent on the AO‟s requirements.

Failure to meet any planning milestones on time shall be identified by the SC and included in the SIMOPS Initiation Approval Form (Appendix 2 – SIMOPS Initiation Approval Form), to be brought to the attention of the appropriate AM for a decision. The advice and support of the department responsible for the activity shall also be sought before a decision is made.

Refer also to the Generic SIMOPS Task list in Appendix

1

.

3.1.1 Scheduling and Lead Time

Sufficient lead-time for efficient planning of work shall be considered as an essential factor for the safe implementation of the SIMOPS program. Typical lead-times for the different phases of the program are as per the following table for stage 1, stage 2 and stage 3 planning.

Table 7. TYPICAL LEAD TIME FOR STAGE 1 OF SIMOPSPLANNING Item Activity Duration (wk) Deliverables

1 Conceptual design

6  PEP Stating the plan of for construction/ maintenance/ commissioning SIMOPS project

2 Detailed design

32  Drawings, process drawings verified onsite

 Necessary provision for construction/ maintenance/ commissioning SIMOPS designed

 Provision for storage of materials  Conversion of instrument gas to air  Risk Assessment requirements incorporated  Final AFC package

 Overall construction, maintenance/ commissioning SIMOPS project  Execution Plan

 Draft Spading Plan 3 Work pack

preparation

16  Requirements checked and confirmed onsite  Final Approved Spading Plan

 Work pack

Table 8. TYPICAL LEAD TIME FOR STAGE 2 OF SIMOPSPLANNING

Item Detailed Design Duration (wk)

1 Mark-up drawings that are as basis for design to show the proposed design Scope of Work including construction/ maintenance/ commissioning SIMOPS provisions.

Identify and procure long lead materials.

2

2 Carry out a work scoping or site visits to verify drawings, especially process drawings, against As-built status of existing facilities.

Check for the general feasibility of executing the proposed design Scope of Work.

Special attention is required for establishing the feasibility of construction (doing more prefabrication and reducing work onsite) / maintenance/ commissioning/ SIMOPS provisions and systems isolation, hydrotest and commissioning plans.

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Item Detailed Design Duration (wk)

3 Carry out detailed design incorporating all work-scoping findings such as as-built status and necessary provisions, especially for construction/ maintenance/ commissioning SIMOPS, for efficient and safe implementation of the project. Procedure “Issued For Approval” (IFA) design package.

Re-identify and produce any additional long lead materials.

24

4 Convene a meeting to review the IFA design package, participation from Safety Operations, Maintenance, Construction and Commissioning personnel shall be sought. Also a Risk Assessment shall be conducted based on the IFA design package, paying special attention to construction/ maintenance/ commissioning SIMOPS requirements.

Consider and incorporate all essential recommendations from the review and risk assessment teams in the design package.

Prepare an overall construction/ maintenance/ commissioning SIMOPS project plan to be included as part of the final AFC package. Procure all other project materials.

4

Sub-Total 32

Table 9. TYPICAL LEAD TIME FOR STAGE 3 OF SIMOPSPLANNING

Item Preparation Duration (wk)

1 Review AFC package – overall construction/ maintenance/ commissioning SIMOPS project plan, drawing M.T.O., etc.

4

2 Prepare Positive Isolation – Spading Plan, verify the inventory, i.e. certified spades and blind flanges, gaskets.

4

3 Carry out a Work-scoping exercise to confirm As-built status and the feasibility of spading plan. Input should be sought from:-

 Operations Installation Manager (OIM)  Work Supervisor (WS)

 Company Site representatives (CSR)

3

4 Incorporate Work-scoping findings in spading plan. Convene a meeting to review the spading plan:-

Participation from Safety Design, Operations, Support, Construction and Commissioning personnel shall be sought.

Procure any additional materials identified during work scoping.

3

5 Issue the work pack sixteen weeks prior to implementation. 1

Sub-Total 15

It is important to note that the durations given above are only to be used as a guide. A specific schedule should be drawn up before the detailed design is to commence. The work pack shall be issued prior to project implementation. This will allow sufficient lead-time for checking and confirming the availability of all materials, equipment and personnel.

3.2 Mandatory Requirements for Initiation & Planning of SIMOPS Programs

A SIMOPS program can only proceed if the risks involved in carrying out the program can be made ALARP and compliance with latest Shell basic requirements for process safety can be demonstrated. The program shall also provide sufficient economic, or strategic, incentive for the work to be carried out simultaneously with production, rather than in shutdown mode: without such incentive, the work can not be carried out as SIMOPS.

The following requirements shall be fulfilled in order for the SIMOPS program to proceed:

 The risks associated with the work have been identified, assessed and demonstrably reduced to a level that is ALARP

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 Compliance with DEM-2 PSBR has been demonstrated – see 3.2.4 below

 HAC drawings accounting for all facilities and activities involved in the SIMOPS have been prepared and approved by the HACC – see 3.2.6

 A MOPO, clearly defining the bounding limits for the SIMOPS, is in place – see 3.2.5

 A CSHC or PHP has been prepared and approved by the appropriate parties – see 3.2.9 below  The host facility where SIMOPS is going to take place (e.g. offshore drilling platform, onshore

production plant etc.) has been prepared in accordance with the requirements of Section 4 of this document

 The SIMOPS program and the associated deferment has been included in the Medium Term RAP by the appropriate IAP forum, and the appropriate Asset Manager has approved the program  Final Pre-SIMOPS inspection, onsite communication and a full emergency drill have taken place.

3.2.1 Hazard Identification and ALARP Risk Assessment

A HAZID and ALARP Risk Assessment exercise shall be carried out for each SIMOPS program, in accordance with BSP-02 Guideline-022 “HAZID” (Ref 11) and BSP-02 Guideline-005 “Guide to Application of BSP HSE Risk Tolerability and Control Acceptance Criteria” (Ref

6

). The purpose of this exercise is to identify all the significant HSE hazards and accident threats associated with a SIMOPS program including, in particular, Major Accident Hazards and Threats (MAH, MAT), and to identify appropriate risk-reducing measures to achieve compliance with BSP ALARP criteria. Furthermore, the study must generate inputs to decisions regarding shutdown and depressurisation of facilities for rig/workboat/barge moves and (heavy) lifting activities, continued use of host facility electrical equipment that is not rated for use in hazardous areas („HAC Zones‟), hot work, local venting and flaring, 3rd

activities, and emergency response including

DEM2 PSBR3 (TR) compliance if any 5B or Red risks are identified in the HAZID.

A conceptual work plan and site layout shall be provided for the HAZID & ALARP exercise. Other information may include host facility integrity data (HC Red Anomalies, Orange TAs and SRIs), status of actions from previous related HEMP studies and Remedial Action plans from relevant HSE Cases, and any relevant incident histories.

The workshop session may also include MOPO development – ref. Section 3.2.5 below.

3.2.1.1 HAZID Team

The AU CPRA / SIMOPS Coordinator (SC) who organizes the HAZID & ALARP exercise shall invite, as a minimum, the following personnel (in addition to himself):

 The main Activity Owners for the SIMOPS i.e. AEO or AEN and/or MPM/xx and/or XPE/3  The AU Senior/Field Operations Supervisor responsible for the SIMOPS host facility/location  The DSV or CSR (or representative thereof) from the Service Unit that will be responsible for

undertaking the SIMOPS activities

 The Senior Representative of the main Contractor engaged to undertake the SIMOPS activities  Structural Engineering (AED/2), Process Engineering (AED/3) and any other engineering

disciplines with a significant role in the SIMOPS activities / design work  SMR - if the SIMOPS involves any marine activities

 HSE Technical Safety and the HSE Advisors for the relevant Asset and Service Units  HAZID & ALARP Process facilitator.

The recommended size for the HAZID Team is 8 - 12 persons.

3.2.1.2 Risk Assessment

Qualitative assessment of HSE risks for each SIMOPS program (i.e. team judgement of risk in qualitative terms) is mandatory. Quantitative Risk Assessment (QRA) is optional, unless the BSP Technical Safety TA and/or HAZID team deem it necessary – see Section 3.2.1.4 below.

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Risks must be assessed against the Shell Group Risk Assessment Matrix (RAM), an image of which is provided in Figure 2 below. Where release of a given hazard has multiple possible outcomes, each outcome must be assessed for risk and the worst case (highest) risk taken as the overall risk for that hazard. Historical experience of accident occurrences serves as a starting point (only) for estimating the likelihood of each potential outcome: specific circumstances must be taken into account in order to arrive at the final assessment of likelihood.

Figure 2. Group Risk Assessment Matrix (RAM), Version 2, December 2009 3.2.1.3 Selection of Hazards and Threats to take forward to the ALARP Study

In essence, Light/Dark Blue risk hazards with established controls do not need any formal documented ALARP demonstration (and therefore do not need to be taken forward from the HAZID to the ALARP Assessment study), whilst Yellow and Red Risk Hazards require a more formal review of the adequacy of their risk controls.

It is neither practical nor necessary to take every identified hazard and threat forward to an ALARP assessment study. Therefore the following criteria are used in selecting hazards and threats to take forward:

 Major Accident Hazards i.e. those with potential accident Severity 5 on the Shell RAM and/or Red Risk (based on historical experience)

 Yellow residual risk hazards (i.e. those still assessed as presenting Yellow Risk after taking account of all specific circumstances and controls in place)

 Any unique unusual project/facility/location specific hazards & threats, for which barriers are not already well-established, or for which the reliability or effectiveness of barriers may be uncertain for any reason.

3.2.1.4 Quantitative Risk Assessment (QRA)

Compliance with BSP Risk Tolerability Criteria can, in many cases, be demonstrated without carrying out a Quantitative Risk Assessment (QRA, i.e. numerical evaluation of the theoretical risks based on a combination of statistics and parametric modelling). However, demonstration of compliance with SCE impairment frequency criteria in Ref. 6, and/or assessment of risk-based justifications for lower risk – higher cost options may be difficult without QRA. Therefore, the HAZID Team, in consultation with the BSP Technical Safety Authority, must consider and decide if a QRA is also required for the SIMOPS program. If a QRA is carried out for the individual SIMOPS program, the potential risk reduction benefit from alternative risk reduction measures and other options can be assessed. If a full QRA is carried out, as opposed to one focused on the modification options, then the overall level of risk for all SCE and people involved can be

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assessed. However, QRA is considered to be most useful for comparison of options, e.g. when the selection of risk reduction measures cannot be established using qualitative assessment methods.

If a QRA is not carried out for an individual SIMOPS program, the results of the QRA in the relevant Operations or NUI HSE case, or past SIMOPS programs, should be used for guidance.

3.2.2 Achieving and Demonstrating ALARP

Assurance that all HSE risks associated with carrying out SIMOPS are being, or will be (via the implementation of Remedial Actions Plans), reduced to a level that is ALARP, is required before the SIMOPS can proceed.

Formal demonstration of ALARP, within the CSHC or PHP, is mandatory for Major Accident Hazards (MAH) i.e. credible accident hazards that potentially fall into the Red Risk area and/or severity level 5 area of the Group RAM. Risk reduction measures are mandatory for Red Risks in order to reduce them to Yellow or Blue.

Yellow Risks need to be reduced to ALARP by identification and implementation of practicable cost-effective risk reduction measures. However, formal demonstration of this for Yellow Risk hazards with consequence Severity of 4 or lower is not required. The process of identifying and implementing „practicable cost-effective risk reduction measures‟ shall consider shutting down and depressurising facilities as one option – with deferment costs to be balanced against expenditure on risk mitigation measures in order to avoid the deferment (see Figure 1).

Hazards within the Dark Blue Risk area need to be managed for continuous improvement in accordance with the HSE-MS and Company Policies.

Hazards within the Light Blue Risk area need to be managed for continuous improvement in accordance with the HSE-MS and Company Policies, although Business may set lower priority for further risk reduction. The ALARP demonstration for each SIMOPS program shall include demonstration of the following:

 Risk Criteria defined in BSP-02 Guideline-005 “Guide to Application of BSP HSE Risk Tolerability

and Control Acceptance Criteria” (Ref.

6

) shall not be exceeded

 The minimum numbers of effective independent risk barriers and escalation factor controls specified in BSP-02 Guideline-005 “Guide to Application of BSP HSE Risk Tolerability and Control Acceptance Criteria” (Ref.

6

)shall be provided for all hazards and accident threats

 Bow-Tie Analysis (BTA) shall be carried out for Hazards that fall into the Red Risk area and/or severity level 5 area of the Group RAM to confirm the number and effectiveness of independent barriers is ALARP and to determine the SC Tasks and SC Positions responsible for them, so that the competence of personnel in SC Positions can be verified for both BSP and Rig personnel, and the integrity of SCE can be verified for both BSP and Rig facilities - see 3.2.2.1 below.

3.2.2.1 Bow Tie Analysis (BTA)

Bow Tie Analysis (BTA) is carried out in order to:

 Identify potential Hazard release, escalation and Consequence scenarios

 Identify the controls (i.e. accident Barriers and Escalation Factor Controls, which constitute HSE-Critical Elements, HSE-HSE-Critical Activities, Tasks and Procedures) required to effectively manage the Risks

 Support the ALARP demonstration

 Provide visibility and communicate the above information to those responsible for managing, or who may be affected by, the Hazards

 In the event of an incident, have the ability to relate causes of incidents to the controls that failed,

Do we need to do a QRA for this SIMOPS Campaign?

If qualitative risk assessment against the Group RAM is not adequate to demonstrate compliance with BSP risk tolerability criteria e.g. due to lack of resolution or uncertainty about final residual risk level, and/or if additional inputs are needed to decisions regarding risk mitigation measures, then the answer is Yes. However, before embarking on new or additional QRA modelling, consideration should be given as to whether results from previous QRAs could be called upon to provide the answers for this SIMOPS campaign.

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thus enabling improved incident learning and prevention.

In accordance with EP Business HSE Control Framework EP2005-0300 HEMP and EP2005-0310 HSE Case, BTA is mandatory for all Major Accident Hazards (MAH) i.e. those hazards with potential for RAM Severity level 5 accident effects and/or Red Risk on the Group RAM.

Bow Ties have been developed for all BSP facilities MAH; these must be reviewed (by „Gap Analysis‟) and, if necessary, extended to account for additional threats or changes to controls during SIMOPS. Also, if the SIMOPS introduces new MAH, then additional Bow Ties will be needed for those MAH – these must be developed as part of the SIMOPS initiation and planning.

The SIEP supported Bow-Tie software package THESIS is the preferred tool for developing and implementing Bow-Ties. Alternatively they can be developed in spreadsheets or a database, and manually depicted.

Reference should be made to the BSP AU and SU Operations HSE Cases, for the latest BSP facilities MAH Bow Ties.

3.2.3 Major Accident Hazard Assessment Sheets (MAHAS)

The CSHC or PHP should include Major Accident Hazard Assessment Sheets (MAHAS) that provide full details of each of the MAH identified for the subject SIMOPS program. The MAHAS detail the nature of the hazard, the threats and consequences from the associated potential Major Accident Events (MAE), a description of the accident barriers and risk controls put in place, including effectiveness review, and a demonstration of ALARP management of the risk.

3.2.4 Requirements from Design Engineering Manual-2 (DEM-2)

Compliance with DEM-2 Process Safety Basic Requirements (PSBR), Ref. 16, is mandatory for all SIMOPS activities and must be addressed in the Initiation and Planning phases of each Program. This mandatory requirement shall also be cascaded down to all contractors involved in the SIMOPS program - requiring them to have compliant facilities and equipment and BSP-accepted HSE Cases demonstrating compliance with DEM-2 PSBR.

Consideration shall be given to the fact that BSP facilities assessed as <5B risk for normal operations may become 5B risk under SIMOPS – in which case, compliance with all PSBRs would be mandatory during SIMOPS.

The main aim of DEM-2 is to prevent re-occurrence of known major Process Safety Incidents, by focussing on their main causes and key Barriers.

Demonstration of compliance of each SIMOPS program with DEM-2 PSBR must be made through the Campaign-Specific HSE Case or SIMOPS PHP, as well as throughout the procedures for the SIMOPS activities and MOPOs (inclusive of Asset) and Contractors‟ HSE Cases.

Brief guidance on all eleven PSBRs is provided in Appendix 6. Specific guidance on PSBR #1 % #3 is provided below, as these are considered to be particularly relevant to SIMOPS programs.

3.2.4.1 PSBR #1 – Siting of Occupied Portable Building (Onshore)

The objective of this requirement is to establish the safe siting distance of portable buildings near live facilities, used to support activities such as pre-shutdown work, concurrent construction and operations, and well services activities. The incident learning from the explosion at BP‟s Texas Refinery in 2005, which resulted in the death of 15 individuals sited in portacabins which are located very near to the processing unit, have been incorporated.

As a result of Physical Effects Modelling, which has been carried out for gas dispersion and potential fires associated with Well blowouts and ruptures of gas lift lines, a safety distance of 60m from production wells and pressurized gas lift lines, is recommended for siting of portable buildings.

For sites where there are process facilities nearby in addition to the wells, e.g. near to SCOT, TGs, etc., then reference should be made to DEP 34.17.10.35-gen (Ref 2) for the minimum safe distance around these.

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 An escape route from the portable building (a door) should always be provided in the wall facing away from the well(s) and flowlines

 Personnel should vacate the portable building during erection of and work-over derricks and masts, and rig down activities, and move clear of the fall radius of the derrick/mast. This standing instruction should be documented in the rig-up / rig-down operations procedures.

3.2.4.2 PSBR #3 - Temporary Refuge (TR)

The provision of adequate Temporary Refuge (TR) during SIMOPS is mandatory for Workboats, Drilling Rigs and Offshore Platforms. Refer detail requirements in DEP 37.17.10.11-Gen Design of Offshore Temporary Refuges (Ref. 1) and DEM-2 PSBR # 3 Gap Closure Action Plan Reports (Ref. 16).

The main function of the TR shall be to provide a place where the total POB can muster without undue risk and have access to the communications, monitoring and control equipment necessary to ensure their personal safety, and from where, if necessary, safe and complete evacuation can be effected.

The functions of the escape and evacuation routes and the embarkation areas shall be to provide, without undue risk to POB:

 Secure means of escape to the TR, and

 Secure means for a complete evacuation from the TR.

In order to demonstrate that the risk of impairment of TR is tolerable & ALARP, it may be3 necessary to carry-out the following HEMP studies, as part of the development of the CSHC or PHP, in order to capture and address TR integrity issues including whether blast overpressure or other immediate effects could impair escape routes, Muster area, Command Support, structural collapse onto the TR, TEMPSC, etc.:

 PEM – Physical Effects Modelling

 EERA – Escape Evacuation & Rescue Assessment  ESSA – Emergency System Survivability Analysis  EFA – Emergency Facilities Assessment

 TRIA – Temporary Refuge Impairment Assessment  QRA – Quantitative Risk Assessment.

3.2.5 Matrix Of Permitted Operations (MOPO)

Safe operating limits for the SIMOPS, within which the prevailing HSE Case(s) and/or PHP are valid, shall be documented in a SIMOPS Matrix of Permitted Operations (MOPO) that defines, for all activities in the SIMOPS program (including production activities):

 Activities that may not be carried out simultaneously with one another  Limits on environmental conditions for all activities

 Limits of safe operations if defences are reduced or removed, in particular if any SCE or EER systems are unavailable / impaired

 Limits of safe operations during periods of increased risk (for any reason not covered above). Reference may be made to BSP-71-Procedure-016 MOPO and EP2005-0300-SP-04 (Ref. 5) for further guidance on the content and structure of MOPOs.

If a pre-existing MOPO e.g. the standard CPRA MOPO (Ref. 30) (note4) is being applied for the SIMOPS program, then this shall be reviewed to ensure that it is valid for the specific circumstances of the program. The SIMOPS MOPO, which supplements but does not replace or override the prevailing Asset Unit MOPO, shall be included in the CSHC / PHP.

3

BSP Technical Safety TA to be consulted regarding which HEMP studies shall be done.

4

At the time of issue of this SIMOPS Manual, standard MOPOs for SIMOPS other than CPRA are planned but not yet developed in accordance with the EP 2005-0300-SP-04 template.

01 BSP-71-Procedure-003 Simultaneous Operations OI - Operating Integrity

Restricted

BSP-71-P

ROCEDURE

-003

S I M U L T A N E O U S

O P E R A T I O N S

( S I M O P S )

R E Q U I R E M E N T S

F O R

M A N A G I N G

A N D

C O N D U C T I N G

E N G I N E E R I N G ,

M A I N T E N A N C E ,

P A I N T I N G ,

D I V I N G ,

W E L L

E N G I N E E R I N G

A N D

W E L L

S E R V I C E S

O P E R A T I O N S

S I M U L T A N E O U S L Y

W I T H

P R O D U C T I O N

O N

B S P

F A C I L I T I E S

Revision

3.0

This Revision of BSP-71-Procedure-003

has been updated and extended to also

cover Well Engineering & Well Services

SIMOPS. As such, this document now

effectively supersedes and replaces

Revision Record

This document has a maximum validity of five years from the last revision date. Within this period it must be

assessed for relevance and re-validated in accordance with BSP

Document Control Procedure

and Section 6.2

Suggestions for further improvement in this document should be sent to the Document Owner.

Distribution

The document owner is responsible for distribution control. The original electronic version is stored in

LiveLink and accessible via BSP OnLine web site. Paper copies are only controlled if they are physically

stamped “Controlled Hard Copy” , signed by the related remote location document controller and recorded in

the BSP71 Master Inventory.

Notice and Warning

Copyright



2012, Brunei Shell Petroleum Company Sendirian Berhad

This document is the property of Brunei Shell Petroleum Company Sendirian Berhad (BSP), Seria KB3534,

Negara Brunei Darussalam. Circulation is restricted to BSP and its designated associates, contractors and

consultants. It must not be copied or used for any other purpose other than that for which it is supplied,

without the express written authority of BSP.

Except where provided for purposes of contractual requirements, BSP disclaims any responsibility or liability

for any use or misuse of the document by any person and makes no warranty as to the accuracy or suitability of

the information to any third party. Any misuse of the document is redressable by BSP.

TABLE OF CONTENTS

Inspection

1

I

N T R O D U C T I O N

1.1 Purpose and Document Structure

1.2 Scope

1.2.1 Well Engineering & Well Services Activities

1.2.2 Construction Activities

1.2.3 Commissioning Activities

1.2.4 Maintenance Activities

1.2.5 Painting Activities

1.2.6 Diving Activities

1.3 SIMOPS Process Overview

1

1.3.1 RASCI Charts

1.4 Terminology

2 R

E S P O N S I B I L I T I E S

1

2.1 SIMOPS Process Forum Responsibilities

2.2 Activity Owner (AO) Responsibilities

_Inspection