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Energy Division Offshore
Offshore Major Hazard
Written Schemes of Examination
(With Focus on Well Examnination)
By James MunroOperations Manager
EUOAG Meeting 3rd – 4th July 2014
Offshore Major Hazard
Written Schemes of Examination
(With Focus on Well Examnination)
By James MunroOperations Manager
EUOAG Meeting 3rd – 4th July 2014
22
Agenda
Key messages on Major Hazard Written Schemes;
Key components of Major Hazard Written Schemes;
Key aspects of Well Examination in detail;
Key findings from Inspections of Well Examination Schemes on the UKCS.
2
33
Energy Division Offshore
Key Messages onMajor Accident
Written Schemes
Key Messages onMajor Accident
Written Schemes
4
Major Hazard Written Schemes
“Success depends on the competence &
independence of the person over your shoulder –the Independent
Competent Person”
3
5
UK Legislation – Major Hazard Written Schemes of Examination
66
Safety CriticalElements (SCE)
Parts of an installation and plantincluding computer software
The failure of which could cause or contribute substantially to
a major accident or prevent or limitthe effect of a major accident
Specified Plant
Plant, procedures & systems forthe detection of incidents that may
Require emergency response. Communication of emergencies,
alarms etc Control of emergencies witha view to limiting the emergency.
Mitigation of Fire & explosion.Evacuation arrangements.
Means of Escape
Any part of a Well
Any part of a well, information,or Work in progress.
(Equipment that falls within the Pressure boundary of the well) so that
there is so far as is reasonably practicable,there can be no unplanned escape offluids from the well or that the risks to
Persons from anything in it are as low as reasonably
practicable
Major Hazard Written Schemes of Examination (Verification)
Independent Competent Person
4
77
Reg 13• No unplanned escape of fluids
throughout the lifecycle of the well
Reg 14• Assessment of conditions below
ground
Reg15• Design with a view to suspension and
abandonment
Reg 16• Suitable Materials
Reg 17• Well control equipment to protect
against blowouts
Reg
21: I
nfor
mat
ion,
Inst
ruct
ion,
trai
ning
& S
uper
visi
on
Reg
18: W
ell e
xam
inat
ion
by In
depe
nden
t C
ompe
tent
Per
son
Wells Design & Construction Regs. 1996
8
Geology
Prognosis AbandonmentDesign
Construction (Drilling the Well)
Handover to Production
Operation/ Production
Maintenance & Workover Interventions
Suspension
Time
Well Examination Scheme must cover the full well life cycle
5
9
Life Cycle Bow Tie Model
HazardousTop
Event
Init
iati
ng
Eve
nts
Legal Prevention & Control Barriers
Co
nseq
uen
cesLegal Mitigation
Barriers
Operation,Maint’e&Mod,
Abandon
Design
Building &Commissioning
ICP & WrittenSchemes
Design
Building &Commissioning
Operation,Maint’e & Mod
Abandon
ICP & WrittenSchemes
1010
Energy Division Offshore
Key Components ofMajor Accident
Written Schemes
Key Components ofMajor Accident
Written Schemes
6
11
Major Hazard Leading Indicators
Remedial Actions Performed[Immediate and Longterm]
MAINTENANCE
Equipment is maintained
in an efficient state,
in efficient working order and in good
repair.
(Unqualified Absolute Duty)
EXAMINATION
To assess suitability,
actual condition,
and determine remedial
measures
Perf / StdFunctionalityAvailabilityReliability
Survivability(Interactions)
Findings/Records
Communicated to Duty holder (Appropriate
level within the management
system)
Duty Holder's/Operator's Safety Management System
Traceability
Written schemes to include arrangements for:ICP SelectionICP IndependenceICP CompetenceICP Comment on List of SCE / SP / wells examinationICP Consultation on SchemeRoles and ResponsibilitiesFor noting any ICP reservationsHow items are identifiedList of items in SchemesChecking suitability for new designsPerformance StandardsNature & Frequency of ExaminationReview of ICP findingsGrading and prioritisation of findingsCommunicating ICP findings to senior management Management and authorisation of deferred actionsRole of Operational Risk AssessmentInvolvement & Role of Onshore Tech AuthorityRemedial Action Plan ManagementRecords ManagementChecking suitability of design of new equipmentTemporary Equipment Systems,etcReview for major repairs, modifications, etc to SCE / SPInterface between verification / SP / wells schemesDH management interface with ICPInfo, instruction & training for those involved with SchemesResolution of disputes between DH & ICPUse of findings as major hazard leading indicatorsRevision and Review and audit of Schemes
Duty Holder PrioritisedRemedial Action Plans
[Immediate and Longterm]
OFFSHORE MAJOR HAZARD WRITTEN SCHEMES OF EXAMINATION UNDER SCR05 & DCR REGULATIONS
Extent of Examination,
Nature, Frequency. Proportional
to Risk
Health and Safety at Work etc Act 1974General Duty: Sections 2 and 3 Offshore Installations (Safety Case)
Regulations 2005, Regulations 2, 19-22 and Schedule 7
PFEER 1995 (11(1)(a), 13, 15 & 16)Note PFEER 19(2) is revoked and now
included in SCR05
DCR 1996 Reg 18
Provision and Use of Work Equipment Regs 1998, Regs 4, 5 and 6: suitability, maintenance and inspection
Design & Construction Regs 1996, Reg 8: Maintenance of Integrity
Prevention of Fire & Explosion Regs 1995, Reg 19(1): Maintenance of Plant
Wells, Design & Construction Regs 1996, Reg 13: General Duty - maintained
Pipeline Safety Regs 1996, Reg 13: Maintenance
IncludesTemporary Equipment/Systems etcas idenitfied
Where the SCE/SP is not functioning or
Perf Std is not achieved, the Duty holder must put in
place operating restrictions to
mitigate effects in an emergency.
Wells:[Well Operator]
Any part of a well, information, or work
in progress.(Equipment that falls within
the pressure boundary of the well)
Proactive use of output of written schemes to investigate and improve the dependability and
suitability of Safety Critical Elements (SCE) and Specified Plant (SP) and any part of a well etc.
Safety Critical Elements (SCE):
Parts of an installation and such of its plant (including computer
programmes) or any part thereof – the failure of which could
cause or contribute substantially to a major accident or prevent or
limit the effect of a major accident.
Responsibility for the written scheme rests with the Duty
Holder or Well Operator
Operational Risk Assessments
should take account of any accumulative
risks associated with multiple SCE/SP performance
issues and involve the onshore
technical authority
Safety Case Reg 8Major Acc HazardsFire, expl'n, release
- death, serious injury. Major damage to structure, loss of
stability, helicopter crash. Diver lift support failure, trapped in bell.
Event - death, serious injury to 5 or more persons.
DCR Reg 18
Wells Exam
Design,
constructed
& maintained
so no
unplanned
escape
of fluids, SFAIRP,
risk to health
& safety are ALARPSpecified Plant (SP):Plant, Proceduresand Systems For:
Detection of incidents that may require emergency response.
Communication of Emergencies - alarms, etc
Control of emergencies with a view to limiting the emergency.
Mitigation of Fire and Explosion.Evacuation Arrangements.
Means of Escape.
PFEER Reg
5
Asses
sment
Event
s -
Majo
r Fire
or
Explos
ion
or
Evacu
ation
,
Escap
e and
Rescu
eSCE / SP Backlog Major
Hazard Leading Indicator
Redesign, modification, new maintenance
procedures, training etc,
Deg
raded P
erform
ance S
tandard = D
egraded
Barriers = Increased R
isks = Lead
ing Indicators
1212
Energy Division Offshore
Key aspects of Well Examination
in Detail
Key aspects of Well Examination
in Detail
7
1313
Competence of the Examiner
Skills
Knowledge
Experience
Regulations, & Industry standards
Subsurface hazard identification;
Well, casing & cement design;
Materials;
Well integrity & Wells SMS
Specialist Areas: HP/HT, deepwater, underbalanced drilling, snubbing,
interventions with a vessel. DP rigs, corrosive env. high angle/ horizontal
wells
Well design including completions;
Well construction including drill, testing & completing
Well operations including integrity management;
Well abandonment;
Risk assessment;
Auditing;
Communications
Other interpersonal skills
1414
Independence of the Examiner
2nd Party 3rd Party
Most Common Least Common
8
15
Industry Guidance & Standards
16
Company Guidance & StandardsSome Examples of Company Standards & Procedures
1. Well Examination Scheme 2. Directional Design & Surveying3. Drill String Design4. Casing design & Kick Tolerance 5. Drilling Operations6. Casing & Cementing Operations 7. Completion Design8. Barrier Policy & Standards9. Well Control & BOPs 10. Well Testing Operations & Equipment11. Well servicing Operations 12. H2S Operations13. Production Well Operations14. Temporary Well Control Equipment15. Risk Assessments & ALARP16. Management of Change17. Dispensation to Standards18. Regulatory Notifications 19. Wells Personnel Competence Assurance/ Training20. Audit and Review Arrangements 21. Interface with Verification Scheme
9
1717
Simplified Well Blowout Bow Tie Model
Blowout
Init
iati
ng
Eve
nts
Barriers for Preventing Loss of Well Control
Co
nseq
uen
cesBarrier for Regaining
Well Control
Kick Prevention
KickDetection
Blowout Prevention
Initial Emer.Response
EmergencyResponse
Well Exam. &Verification
Well Exam. &Verification
Freq. of blowout:HPHT 1.86 E-3
Exp. 3.0E-4Dev. 7.9E-5
Shallow gas:HP/HT 2.08E-3Dev. 1.59E-3
No effect if water depth >300m
Probability of ignition:0.1
Ignition of subsea blowout likely not to occur
wind >3m/s, wave>2.5m
Well Kill Operations
Environmental Mitigation: Capping / Relief well
/ clean up
Well Kill Operations (?)
?
18
Drilling Operations
Well proposal
Well basis of design
Drilling ProgrammeCasing design/
Kick tolerance
Testing programme
Suspension & abandonment
programme
Government Notifications
ICP Examines
Daily reports
Drilling the well on paper
10
19
Completion Operations
Completion basis of design
ICP Examines
Tubing Stress Analysis Report
Completion programme
20
Well Intervention / Workovers
Well status and diagrams
ICP Examines
Intervention/ workover programme
Re- completion design &
programme
11
21
Production wells
Production well annulus
integrity reports
Tree & wellhead test
reports
DHSV test results
Corrosion monitoring
reports
Conductor condition reports
ICP Examines
Tree & wellhead test maintenance
reports
2222
Energy Division Offshore
Key Findings fromInspections
of Well Examination
Schemes
Key Findings fromInspections
of Well Examination
Schemes
12
23
Key Findings fromInspections
Ownership & responsibility for the Scheme
Inclusion of all wells
Life cycle of well
Interface with the installation Verification Scheme
All modifications including minor ones
Inclusion of mobile equipment
Independence & competence of examiner
Information, instruction training & supervision of staff
Guidance on ALARP
Resolution of disputes
Audit
24
What the law requires!
RealityOffshore?
The Regulator’’’’s Challenge
13
2525
Energy Division Offshore
Thank you for listeningThank you for listening
