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

Brunei Shell Petroleum Company Sendirian Berhad

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BSP-71-PROCEDURE-003

SIMULTANEOUS OPERATIONS (SIMOPS)

REQUIREMENTS FOR MAN AGING AND CONDUCTING ENGINEERING, MAINTENANCE, P AINTING, DIVING, WELL ENGINEERING AND WELL SERVICES OPERATIONS SIMULTANEOUSLY WITH PRODUCTION ON BSP FACILITIES

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 BSPACT-P-01 CPRA Process Manual

Revision 3.0

Owner: Authors:

BSP-AD Hjh Rosmawatty Hj Abd Mumin HSE/61 Abd-Razak Hj Abu Bakar, OPM/35 Hazliana Hj Bolhassan

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Revision Record Rev 0

Revision description

Date

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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TABLE OF CONTENTS 1

INTRODUCTION ................................................................................................................................. 6 1.1 1.2

Purpose and Document Structure ........................................................................................................... 6 Scope ...................................................................................................................................................... 6 1.2.1 Well Engineering & Well Services Activities ..................................................................... 7 1.2.2 Construction Activities ...................................................................................................... 7 1.2.3 Commissioning Activities .................................................................................................. 7 1.2.4 Maintenance Activities ...................................................................................................... 8 1.2.5 Painting Activities ............................................................................................................. 8 1.2.6 Diving Activities ................................................................................................................ 9 1.3 SIMOPS Process Overview .................................................................................................................... 9 1.4 Terminology .......................................................................................................................................... 11

2

RESPONSIBILITIES ......................................................................................................................... 14 2.1 2.2 2.3

SIMOPS Process Forum Responsibilities ............................................................................................. 14 Activity Owner (AO) Responsibilities ..................................................................................................... 14 Asset Unit Responsibilities .................................................................................................................... 15 2.3.1 Asset Manager (AM) ....................................................................................................... 16 2.3.2 Asset Engineer (AE) ....................................................................................................... 16 2.3.3 AU CPRA / SIMOPS Coordinator (SC) ........................................................................... 16 2.3.4 Person-In-Charge (PIC).................................................................................................. 17 2.4 Rolling Activity Planning (RAP) Forum .................................................................................................. 17 2.5 SIMOPS Process Manual Custodian .................................................................................................... 17

3

INITIATION & PLANNING OF SIMOPS PROGRAMS ..................................................................... 18 3.1

Planning Milestones .............................................................................................................................. 18 3.1.1 Scheduling and Lead Time ............................................................................................. 18 3.2 Mandatory Requirements for Initiation & Planning of SIMOPS Programs ............................................. 19 3.2.1 Hazard Identification and ALARP Risk Assessment ....................................................... 20 3.2.2 Achieving and Demonstrating ALARP ............................................................................ 22 3.2.3 Major Accident Hazard Assessment Sheets (MAHAS) ................................................... 23 3.2.4 Requirements from Design Engineering Manual-2 (DEM-2) .......................................... 23 3.2.5 Matrix Of Permitted Operations (MOPO) ........................................................................ 24 3.2.6 Hazardous Area Classification........................................................................................ 25 3.2.7 Planning of Heavy Lifts ................................................................................................... 25 3.2.8 Scaffolding Plans ............................................................................................................ 25 3.2.9 Project HSE Plans (PHP) and Campaign-Specific HSE Cases (CSHC) ........................ 26 3.2.10 Bridging Document ......................................................................................................... 28 3.2.11 Statement Of Fitness ...................................................................................................... 28 3.2.12 Special Considerations for Manned Facilities ................................................................. 28 3.2.13 Classification of SIMOPS Activities ................................................................................ 29 3.3 SIMOPS Change Control ...................................................................................................................... 31 3.4 Deviation Management ......................................................................................................................... 32

4

SITE / FACILITY PREPARATION FOR SIMOPS ............................................................................. 33 4.1

Pre-SIMOPS Inspections and Repairs .................................................................................................. 33 4.1.1 Platform Structure........................................................................................................... 34 4.1.2 Subsea Pipelines ............................................................................................................ 34 4.1.3 Site / Seabed .................................................................................................................. 34 4.1.4 Piping, Vessels (separators, tanks) and Risers .............................................................. 34 4.1.5 Wells and Well Equipment .............................................................................................. 34 4.1.6 Instrumentation and Electrical Equipment ...................................................................... 35 4.2 Fire & Gas Detection and Alarms .......................................................................................................... 35 4.2.1 Gas Detection ................................................................................................................. 35 4.2.2 Fire Detection ................................................................................................................. 36 4.2.3 Alarms ............................................................................................................................ 36 4.3 ESD system and Kill Knobs .................................................................................................................. 36

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4.4

4.5 4.6 4.7 4.8

5

5.3 5.4

5.5 5.6 5.7 5.8

5.9 5.10

5.11

5.12

5.13

5.14 5.15 5.16

Single Point Accountability .................................................................................................................... 40 Communication ..................................................................................................................................... 40 5.2.1 Pre-SIMOPS Meeting ..................................................................................................... 40 5.2.2 Daily SIMOPS Meeting ................................................................................................... 40 5.2.3 SIMOPS Toolbox Meetings ............................................................................................ 40 5.2.4 Communications Equipment, Telephone Numbers and Radio Channels ....................... 40 Arrival of the Drilling Rig/Workboat/Barge and SIMOPS Equipment ..................................................... 41 5.3.1 Anchor Patterns .............................................................................................................. 41 Custody of Facilities .............................................................................................................................. 42 5.4.1 Custodian Responsibilities ............................................................................................. 42 5.4.2 Hand-Over of Facilities ................................................................................................... 42 5.4.3 Facility Hand-Over and Hand-Back Check Lists ............................................................. 43 5.4.4 Delegation of Responsibility ........................................................................................... 43 Helideck Removal/Replacement and Rig-Up and Rig-Down ................................................................ 43 Other (Heavy) Lifts and Equipment Moves ........................................................................................... 44 Station Start-Up .................................................................................................................................... 45 Permit to Work (PTW) ........................................................................................................................... 45 5.8.1 PTW Restrictions ............................................................................................................ 46 5.8.2 Supervision of Multiple Activities .................................................................................... 46 Depressurising – Flushing – Purging – Venting (DFPV) ....................................................................... 46 Double Protection Barriers and Positive Isolation ................................................................................. 46 5.10.1 Positive Isolation............................................................................................................. 47 5.10.2 Isolation and Spading Implementation............................................................................ 47 Testing and inspection of new or modified pipework ............................................................................. 47 5.11.1 Hydrotest and Re-instatement Test ................................................................................ 47 5.11.2 NDT Inspection............................................................................................................. 47 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 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 Underwater Activities ............................................................................................................................ 54 Shift Changes During SIMOPS Programs............................................................................................. 54 Emergency Response ........................................................................................................................... 54 5.16.1 On Scene Commander (OSC) ........................................................................................ 54 5.16.2 Emergency Escape ........................................................................................................ 55 5.16.3 Emergency Response Drill ............................................................................................. 55

MANAGEMENT REVIEW ................................................................................................................. 56 6.1 6.2 6.3

7

4.3.1 “Live” Area Identification ................................................................................................. 37 Conversion of Instrument & Power Gas Systems to Compressed Air ................................................... 37 4.4.1 Air Compressor............................................................................................................... 37 4.4.2 Nitrogen (N2) Purge ........................................................................................................ 38 Impact Protection .................................................................................................................................. 38 Chemical Injection ................................................................................................................................. 38 Drip Pans, Drains and Sumps ............................................................................................................... 38 Local Vents and Flares ......................................................................................................................... 38

EXECUTION OF SIMOPS PROGRAMS .......................................................................................... 40 5.1 5.2

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After Action Reviews ............................................................................................................................. 56 BSP71-Procedure-003 SIMOPS Process Manual Updates .................................................................. 56 Audits of CSHC‟s and PHP‟s ................................................................................................................ 56

REFERENCES .................................................................................................................................. 57

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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. Table 2. Table 3. Table 4. Table 5. Table 6. Table 7. Table 8. Table 9. Table 10. Table 11. Table 12. Table 13. Table 14. Table 15. Table 16. Table 17. Table 18.

Generic SIMOPS Process Phases, Activities & Responsible Parties......................................................... 9 Process Flow for a typical Engineering / Maintenance SIMOPS Program or Campaign ............................ 9 Process Flow for a Typical Drilling or Well intervention SIMOPS Program or Campaign........................ 10 Definitions ................................................................................................................................................ 11 SIMOPS Process Forum Responsibilities ................................................................................................ 14 Asset Unit Responsibilities ....................................................................................................................... 15 Typical Lead Time for Stage 1 of SIMOPS Planning................................................................................ 18 Typical Lead Time for Stage 2 of SIMOPS Planning................................................................................ 18 Typical Lead Time for Stage 3 of SIMOPS Planning................................................................................ 19 Special Issues For SIMOPS At Normally-Manned Facilities .................................................................... 28 Pre-SIMOPS Inspection Checks .............................................................................................................. 33 Well Equipment Checks ........................................................................................................................... 34 Default Platform Shutdown and Depressurisation Requirements for Final Move-in and Positioning ....... 41 Facilities Hand-Over Default Rules .......................................................................................................... 42 Default Platform Shutdown and Depressurisation Requirements for Helideck Lifts and Rig-Up/Down involving Heavy Lifts................................................................................................................................ 44 Default Platform Shutdown and Depressurisation Requirements for Other (Heavy) Lifts and Equipment Moves ...................................................................................................................................................... 44 PTW Restrictions for Hot Work in HAC zones ......................................................................................... 48 Summary Of Restrictions On Blast Cleaning In HAC Zones .................................................................... 53

FIGURES Figure 1 Figure 2 Figure 3

SIMOPS Justification Balance .................................................................................................................. 16 Group Risk Assessment Matrix (RAM), Version 2, December 2009 ......................................................... 21 Process Procedure for Approval of Third Activities ................................................................................... 31

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INTRODUCTION

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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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):   

1

Drilling rig and WIU Barge movements and rig-up/rig-down 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 2 activities or as off-line third activities : o o o o o o o o o ii.

1.2.2

Perforating Stimulation (Acidising) Fracturing Well kick-off (including use of N2) Logging Securing (well killing) CTU and Wireline/Slickline operations while the Rig or WIU is present Conductor driving Grouting.

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.

Construction Activities

Typical Construction activities (on a live production facility) within the scope of this manual include:            

1.2.3

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.

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

See Section 3.2.13 for the definition of First, Second and Third Activities

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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:   

1.2.4

Mechanical equipment, and associated vessels and systems Electrical installations and instrument systems Safety and fire fighting systems.

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:              1.2.4.2

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. 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:         

1.2.5

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.

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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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. Phase Initiation

GENERIC SIMOPS PROCESS PHASES, ACTIVITIES & RESPONSIBLE PARTIES

Accountable Party

Activities & Responsible Parties

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 / M AINTENANCE SIMOPS PROGRAM OR CAMPAIGN

Phase Initiation

Task 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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Milestone Guide*

- 12 months

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Planning

Execution

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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

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

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

12

Carry out SIMOPS

13

Post-SIMOPS verifications before production start up

14

Conduct After Action Review (AAR)

-16 weeks

+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 SIMOPS PROGRAM OR CAMPAIGN

URL Link to Process Flow for A Typical Drilling or Well Intervention SIMOPS Program or Campaign

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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. Abbreviation/Term AAR Accountable Accountable person

AE AED AEN AEO AFC Aka ALARP

AM Anomaly AO AU BFD BTA Consulted CPRA CPEMA CPPA CSHC CSR

DEFINITIONS

Meaning After Action Review 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 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. Asset (Maintenance Support) Engineer Asset Engineering Design (BSP department) Engineering & Construction Onshore (BSP department) Engineering & Construction Offshore (BSP department) Approved For Construction also known as 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. Asset Manager A defect, resulting from corrosion or erosion, detected on process piping, risers, vessels or structures. Activity Owner e.g. AEO, TSW (see also „WAO‟) Asset Unit Basis For Design Bow Tie Analysis Shall be consulted by the Responsible party on activities and results. The Consulted Party must be given an opportunity to contribute Concurrent Production and Rig Activities (i.e. Well Engineering SIMOPS) Concurrent Production, Engineering and Maintenance Activities (SIMOPS) Concurrent Production and Painting Activities (SIMOPS) Campaign-Specific (SIMOPS) HSE Case (see Section 3.2.9.2) Company Site Representative

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Abbreviation/Term CTU DFPV DP DSV EC ECT EERA EFA EPA ER ESSA ESD ESDV ETRER EWIMS F&G FOG FRED GSS HAC / HACC Hand-over HAZAN HAZID HC HEMP HiPo HSE IA IAP IG IFA Informed IPOP JHA JU LFL LIPPs LOC MAH MAHAS Manned Facility MAT MODU MOPO MPM MPFM MSL NPT NUI OIM OM OSC PA PAR PEC PEP PEM

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Meaning Coiled Tubing Unit Depressurising – Flushing – Purging – Venting Drilling Platform Drilling Supervisor Emergency Coordinator Emergency Coordinator Team Escape Evacuation & Rescue Assessment Emergency Facilities Assessment Shell Exploration and Production Asia Pacific Emergency Response Emergency System Survivability Analysis Emergency Shutdown Emergency Shutdown Valve Escape, Temporary Refuge, Evacuation and Rescue Electronic Well Integrity Management System Fire & Gas (detection) Falling Objects Guide Fire, Release, Explosion and Dispersion modelling software General Shift Supervisor Hazardous Area Classification / Hazardous Area Classification Committee (see „Zone‟ definitions below) The transfer of custody from one department to another department. This is considered a temporary change of ownership of the platform. Hazard Analysis, including phenomenological modelling such as FRED hazard range assessments Hazard identification exercise. A “desk-top” evaluation exercise carried out to identify and document all hazards associated with a particular activity Hydro Carbons Hazards and Effects Management Process High Potential (used in reference to any incident with high potential for a serious accident) Health, Safety and Environment Instrument Air Integrated Activity Plan Instrument Gas Issued For Approval Informed. Shall be informed about decisions, activities and results Integrated Planning On Paper Job Hazard Analysis Jack-Up 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) Lightweight Impact Protection Plates Loss of Containment 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 Major Accident Hazard Assessment Sheets A facility that has people permanently located on it and has permanent living quarters Major Accident Threat Mobile Offshore Drilling Unit Manual Of Permitted Operations Major Projects (Department of BSP) Multi-Phase Flow Meter Mean Sea Level Non Productive Time Normally Unmanned Installation Operations Installation Manager Operations Manager i.e. Head of Operation (XOPs) On Scene Commander Public Announcement Piping Anomaly Report Plan Entry Criteria Project Execution Plan Physical Effects Modelling

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Abbreviation/Term PHP PIC PIP PL POB PM Production Activities PSBR PTB PTW QRA RAM RAP RASCI ROV SAR SC SCE SCSSSV SIMOPS

SOS SRI SSOW SSV SU TA TR TRIA Unmanned facility WAO WIU WJ WS Zone 0

Zone 1

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Meaning Project HSE Plan (see Section 3.2.9.1) Person In Charge Permit In Place Project Leader Personnel On Board Preventative Maintenance Activities related to producing of hydrocarbons i.e., “live” facilities. Process Safety Basic Requirements Personnel Transfer Bridge (aka Gangway) Permit To Work Quantitative Risk Assessment Risk Assessment Matrix Rolling Activity Plan Responsible, Accountable, Support, Consult, Inform. Remotely Operated Vehicle Structure Anomaly Report SIMOPS Coordinator (aka „CPRA Focal Point‟ in the case of well engineering SIMOPS) Safety Critical Element Surface-Controlled Subsurface Safety Valve “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 Senior Offshore Supervisor Safety Related Item Safe System Of Work Surface safety valves Service Unit Technical Authority Temporary Refuge Temporary Refuge Impairment Assessment A facility that does not have people permanently located on it, although it may be visited regularly. Well Activity Owner Well Intervention Unit Well Jacket Work Supervisor 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. 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. 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 RESPONSIBILITIES 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.

SIMOPS PROCESS 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. Category

Description

HSE



Operations

Engineering

Economic assessment

ASSET UNIT RESPONSIBILITIES

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.



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.



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.



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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Responsibility XOP/1 XOP/5

XOP/1

XOP/1

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Category

Description

Review



Training

2.3.1



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Responsibility

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

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

XOP/1

XOP/5

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.

2.3.2

SIMOPS Justification Balance

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.

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:

2.4



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).

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



The generic SIMOPS Procedure is updated, as necessary, to reflect the outcome of AAR‟s.

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3 INITIATION & PLANNING 3.1

OF

SIMOPS PROGRAMS

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 SIMOPS PLANNING

Item

Activity

Duration (wk)

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. Item 1

Deliverables

TYPICAL LEAD TIME FOR STAGE 2 OF SIMOPS PLANNING

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

Duration (wk) 2

Identify and procure long lead materials. 2

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

2

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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Detailed Design

Duration (wk)

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.

24

Re-identify and produce any additional long lead materials. 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.

4

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. Sub-Total

32

Table 9. Item

TYPICAL LEAD TIME FOR STAGE 3 OF SIMOPS PLANNING

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:-

3

 Operations Installation Manager (OIM)  Work Supervisor (WS)  Company Site representatives (CSR) 4

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

3

Participation from Safety Design, Operations, Support, Construction and Commissioning personnel shall be sought. Procure any additional materials identified during work scoping. 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 rd areas („HAC Zones‟), hot work, local venting and flaring, 3 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. 3.2.1.3

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

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. 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.

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 costeffective 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 HSECritical Elements, 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,

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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