KP4: Ageing and Life Extension - Inspection Template - Wells
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KP4: Ageing and Life Extension - Inspection Template - Wells
KP4: Ageing and Life Extension - Inspection Template - Wells INSTALLATION or DUTYHOLDER DATES(S) IMT and INSPECTOR(S) Key Persons interviewed Company Position Summary of Inspection Traffic Lights Red Amber Green W 6 5 4 3 2 1 0 Section A: Ageing and Life Extension(Degradation & Deterioration) (ALE) - Policy Section B: ALE - Organising Section C: ALE - Planning and Implementing Section D: ALE - Measuring Performance Section E: ALE - Auditing and Reviewing Performance Summary of Inspection Findings: HSE Action taken: September 2011 V1.0 Page 1 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section A: Ageing & Life Extension - Policy and Leadership (Questions for senior management – typically Well Integrity Technical Authority) Principal Questions: 1. Describe the policies that senior management have put in place for integrity management of safety critical elements and in particular ageing and life extension(degradation & deterioration) issues. 2. To what extent are senior managers aware of the performance of the systems designed to maintain the integrity of safety-critical assets, and what is their commitment to ensuring that such assets remain fit for service at all times? Benchmarks sought in replies: Explicit recognition of the significance of ageing (degradation & deterioration) issues Understanding of the challenges to degradation & deterioration issues Ageing and life extension (degradation & deterioration) policy owned by senior management Senior management has responsibility for implementing degradation & deterioration policy Senior management support for equipment/system replacement Asset Integrity Management addresses degradation & deterioration Fitness for purpose demonstrations are described References to codes, standards & guidance, for example: o OSD Info sheet 4/2009 o Plant Ageing HSE RR 509 o Energy Institute ‘Framework for monitoring the management of ageing effects on safety critical elements’ Supplementary Questions: The duty holder shall demonstrate that wells asset integrity management policy exists and that it is a cyclical process comprising planning, implementation and evaluation. A-1. Does a wells asset integrity policy exist? Is it a cyclical and continuous process? A-2. Does the wells asset integrity policy include planning, implementation, and evaluation stages? A-3. Does the wells asset integrity policy specifically address life-extension beyond the original design? A-4. Does the wells asset integrity policy include management of the approach to assessing the ageing (degradation & deterioration) processes and the need to link inspection requirements to these? The duty holder shall demonstrate that the well integrity management system is fit-for-purpose. A-5. Is an extension of service life beyond the original calculated design life proposed or has one been implemented? A-6. Has damage or deterioration to critical plant, equipment or components occurred? A-7. Has there been a change-of-use that violates the original design or previous integrity assessment? A-8. Has there been a departure of operating conditions pressures or loading, etc., from the original basis of design? A-9. Has the duty holder re-assessed any part of the design where standards are known to September 2011 V1.0 Page 2 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section A: Ageing & Life Extension - Policy and Leadership have been updated to reflect improved knowledge and experience? A-10. Has the duty holder re-assessed any part of the design for plant or equipment components that are showing indications of ageing? The duty holder shall demonstrate that fitness-for-purpose evaluations are sufficiently detailed. A-11. Have the all appropriate factors been considered in fitness-for-purpose evaluations? (e.g., age vs. design life, condition including ageing, original design vs. current knowledge, reserve strength and redundancy, modifications and repairs, change of use, etc.) A-12. Have the fitness-for-purpose evaluations considered factors which may affect performance, including: - plant & equipment age and design life; - condition (including damage or deterioration of components); - the original design criteria - information that demonstrates that the original design criteria are invalid; - the degree of redundancy; - modifications, additions, repairs or strengthening; - change of use that violates previous integrity assessments; - departures from the original basis of design; - the versions of the design codes used; - consideration of interaction of failure mechanisms. The duty holder shall demonstrate a general understanding of ageing & life-extension (degradation & deterioration) issues as an essential component of Wells Asset Integrity Management. A-13. What does the DH consider to be the principal degradation & deterioration issues that affect well operations plant & equipment integrity – during the lifecycle of the well? A-14. Has a gap analysis been performed? The duty holder shall demonstrate the existence of a clear and appropriate corporate policy on degradation & deterioration for the “well envelope”. A-15. Does the duty holder have in place a clear corporate policy on degradation & deterioration for wells ? A-16. Is the corporate policy on sufficient in its scope and breadth? A-17. Does the corporate policy on degradation & deterioration for wells form an essential part of the overall Asset Integrity Management System? A-18. What guidance is available for “well envelope” degradation & deterioration issues contribution to safety cases, thorough reviews and well notifications? A-19. What risks have been identified from degradation & deterioration issues in relation to the “well envelope”? A-20. Have these risks been incorporated into the Asset Integrity Management System system? September 2011 V1.0 Page 3 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section A: Ageing & Life Extension – Policy and Leadership Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NON-COMPLIANCE SIGNIFICANT NONCOMPLIANCE GENERAL NON-COMPLIANCE PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Court proceedings recommended 6 Enforcement Notice Served Letter & changes made to intervention 4 Letter Verbal advice No findings 3 2 1 5 September 2011 V1.0 NOT INSPECTED 0 Page 4 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section B: Ageing & Life Extension - Organising (Questions for senior management – typically Well Integrity Technical Authority) Principal Questions: 1. What management processes are in place to ensure delivery of the policy? 2. How does the leadership team know that the people involved are competent to perform the duties that the leadership team expect them to perform? Benchmarks sought in replies: Roles and responsibilities are defined Defined responsibility for condition assessments & life extension (degradation & deterioration) studies Management & development of personnel competency Management of contractor and 3rd party competency Retention of corporate knowledge Documentation management (asset registers / drawings) Management of change Supplementary Questions: The duty holder shall demonstrate that an effective management structure is in place for delivering the ageing & life-extension (degradation & deterioration) policy for Wells. B-1. How is the ageing & life-extension (degradation & deterioration) policy communicated throughout the organisation? How are changes or updates to the policy communicated? B-2. Is the policy underpinned by staff involvement and participation? Is there a mechanism in place for staff feedback? The duty holder shall demonstrate that the need for competency in ageing & life-extension (degradation & deterioration) issues for Wells and asset integrity management is recognised and incorporated into the policy. B-3. Does the duty holder employ sufficient and appropriate competencies to identify ageing (degradation& deterioration) mechanisms, evaluate the extent of ageing, and implement mitigation measures? B-4. Who is responsible for conducting drilling & well operations plant & equipment condition assessments and determining any limitations on future use? B-5. Do those responsible for managing, inspecting & maintaining plant & equipment have an adequate understanding of ageing issues? How are key issues, signs or symptoms being communicated to operations or maintenance personnel so they are aware of what to be alert to as indicators of ageing plant? B-6. Are those responsible for managing, inspecting & maintaining plant & equipment aware of the current standards and guidance? Are these applied consistently and appropriately? B-7. Does the duty holder have access to specialist skills and knowledge on ageing mechanisms and their management? (e.g., instrumentation & control engineers, corrosion engineers, fire & explosion specialists, etc.) B-8. To what extent does the duty holder employ contractors or other third-parties for well integrity inspection and maintenance activities? How are they selected, assessed for competency and monitored for performance? September 2011 V1.0 Page 5 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section B: Ageing & Life Extension - Organising B-9. How does the duty holder ensure that key competencies, knowledge and experience, etc., relevant to well integrity and degradation & deterioration issues are not lost permanently when staff retire, transfer or otherwise leave? B-10. What provisions are in place to retain operational and maintenance records? Is there a plan in place to convert paper records to digital records? B-11. What arrangements are in place to ensure a smooth transition of information during a change of ownership? September 2011 V1.0 Page 6 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section B: Ageing & Life Extension – Organising Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NON-COMPLIANCE SIGNIFICANT NONCOMPLIANCE GENERAL NON-COMPLIANCE PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Court proceedings recommended 6 Enforcement Notice Served Letter & changes made to intervention 4 Letter Verbal advice No findings 3 2 1 5 September 2011 V1.0 NOT INSPECTED 0 Page 7 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section C: Ageing & Life Extension - Planning and Implementing (Questions for senior management – typically Well Integrity Technical Authority) Principal Questions: 1. What steps are being taken to ensure the implementation of the Ageing & Life Extension(Degradation and Deterioration) policy for Wells? 2. Explain how the Well Integrity Management System captures ageing issues. 3. Describe the performance indicators used to indentify ageing (degradation & deterioration) of SCEs Benchmarks sought in replies: Explanation of how equipment subject to ageing (degradation & deterioration) is selected and identified Review of the suitability of the performance standards Assessment of operation beyond design life Evaluation of wear, deterioration and damage in service Review for operation outside of design limits, and for changed design standards Obsolescence identified and managed Plans for replacement and provision of spares Targeted inspection and maintenance, including difficult to access equipment Life extension studies and fitness for purpose demonstrations Supplementary Questions: The duty holder shall demonstrate that an effective inspection and maintenance plan is in place. C-1. Does the duty holder review the operation and maintenance histories to identify equipment and plant that may have been subject to ageing (degradation & deterioration) processes? C-2. To what degree is the service life or life cycle of plant & equipment understood? C-3. Has any part of the installation experienced recurring defects, or increasing trends of unplanned work and breakdowns? What measures are being used to manage these aspects? C-4. Are there arrangements in place to identify plant & equipment that is approaching or has exceeded its original design life? C-5. Are there arrangements in place to compare remaining-life estimates with original design lives? C-6. Does the duty holder utilise a third-party integrity management organisation? If so, to what extent is the duty holder involved with the inspection planning and implementation process? C-7. What is the basis of the inspection plan (e.g., risk-based or time-based)? Has the inspection regime changed from time-based to risk-based since the plant was constructed? C-8. Has there been any increase to the extent of inspection, frequency or any change to the inspection regime from fixed periods to a risk-based regime? This may be an indicator of ageing(degradation & deterioration) and a response to the inspection findings. What measures are being used to manage these aspects? C-9. Is there a clear system in place by which the inspection plan is implemented? (e.g., system inspection work packs, etc.) C-10. Is there a clear process in place to handle intentional, or otherwise, deviations from the inspection plan? September 2011 V1.0 Page 8 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section C: Ageing & Life Extension - Planning and Implementing C-11. Are there arrangements in place to maintain an up-to-date asset register? (e.g., plant, equipment, piping lists, etc.) C-12. Are items found to be suffering from ageing (degradation & deterioration) identified, highlighted and given special attention (e.g. in risk based inspection reports, or in written schemes of examination?) C-13. Is there a clear process in place to verify agreement or identify discrepancies between reality and as-built documentation? How are modifications, alterations, etc., incorporated into the well integrity management system? C-14. How is safety critical equipment identified? The duty holder shall demonstrate that plant & equipment that is difficult to inspect or maintain has been identified. C-15. What plant & equipment have been identified as difficult to inspect or maintain? C-16. How is out-of-date or obsolescent plant or equipment identified and managed to ensure integrity and performance (including equipment that may no longer be supported by the supplier or manufacturer)? September 2011 V1.0 Page 9 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section C: Ageing & Life Extension - Planning and Implementing Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NON-COMPLIANCE SIGNIFICANT NONCOMPLIANCE GENERAL NON-COMPLIANCE PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Court proceedings recommended 6 Enforcement Notice Served Letter & changes made to intervention 4 Letter Verbal advice No findings 3 2 1 5 September 2011 V1.0 NOT INSPECTED 0 Page 10 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section D: Ageing & Life Extension - Measuring Performance (Questions for senior management – typically Well Integrity Technical Authority) Principal Questions: 1. How does senior management know that the risks arising from Ageing & Life Extension(Degradation and Deterioration) of Wells are being effectively controlled? 2. Describe the performance indicators used to demonstrate the current condition of the installation “well envelope” plant and equipment. Benchmarks sought in replies: Leading and lagging KPIs to monitor impact of ageing & life extension (degradation & deterioration) on the well envelope are defined Management reviews KPIs and acts Contractor and 3rd party maintenance findings reviewed Procedures in place to detect ageing & life extension (degradation & deterioration) Ageing & life extension (degradation & deterioration) processes monitored Failure trends identified Supplementary Questions: The duty holder shall demonstrate an adequate understanding and knowledge as to the current status of integrity of well envelope plant & equipment. D-1. To what extent is the current condition of plant & equipment known? D-2. To what extent is the remaining life of plant & equipment known? D-3. Does the duty holder continuously and routinely update remaining lives? The duty holder demonstrates an adequate system by which performance is measured. D-4. What specific key performance indicators (KPIs), 'traffic lights' or similar are used to review plant and equipment condition? D-5. What information about ageing & life extension (degradation & deterioration) is covered by the well examination scheme D-6. Does the duty holder identify key plant & equipment performance indicators along with its availability & reliability targets? D-7. Describe how the inspection techniques are appropriate for the detection of ageing or deteriorating performance? Is the frequency and scope of the inspection sufficient? D-8. Has the duty holder specified leading and lagging indicators? D-9. What leading or lagging indicators are used to indicate assets that may not be performing as required or showing signs of deterioration in their integrity or performance? D-10. Does the duty holder evaluate the implications of revised or new codes, standards, guidelines, etc., and adapt plant & equipment inspection and maintenance, etc., where necessary? D-11. Is appropriate reference made to codes, standards, recommended practices, guidelines, etc., relevant to ageing & life-extension and asset integrity management ? The duty holder shall demonstrate that a process is in place to monitor degradation & deterioration D-12. What methods are in place to record information relating to ageing (degradation & deterioration)? September 2011 V1.0 Page 11 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section D: Ageing & Life Extension - Measuring Performance D-13. Has any well envelope equipment & plant been identified as ageing (degradation & deterioration)? (e.g., creep, cracking, corrosion, etc.) If so, what measures are being taken to manage these issues? D-14. Has any well envelope equipment & plant been identified that is approaching or has exceeded its original design life? D-15. Has any well envelope plant & equipment been identified as ageing (degradation & deterioration), and if so, how was this identified or discovered and what is being done to manage this? D-16. What well envelope equipment & plant prone to ageing and deterioration have a history of operation at the limit of, or beyond, the original design? D-17. How is the condition of the well envelope equipment & plant, which is approaching or beyond its original design life monitored and assessed? D-18. How is the remaining life of well envelope equipment & plant calculated? How is the endpoint defined? Who performs the calculations? D-19. Where remaining-life calculations suggest an extension of service life beyond the design life, or the design life is approaching, are formal life-extension calculations and studies performed? September 2011 V1.0 Page 12 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section D: Ageing & Life Extension - Measuring Performance Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NON-COMPLIANCE SIGNIFICANT NONCOMPLIANCE GENERAL NON-COMPLIANCE PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Court proceedings recommended 6 Enforcement Notice Served Letter & changes made to intervention 4 Letter Verbal advice No findings 3 2 1 5 September 2011 V1.0 NOT INSPECTED 0 Page 13 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section E: Ageing & Life Extension - Auditing and Reviewing Performance (Questions for senior management – typically Well Integrity Technical Authority) Principal Questions: 1. How does the duty holder review the effectiveness of their inspection, maintenance and repair activities? 2. Describe the processes in place to audit the ageing and life extension (degradation & deterioration) of well envelope aspects of their integrity management system. 3. Describe how the verification system is used to address deterioration associated with ageing and life extension issues. Benchmarks sought in replies: Formal audit programme which addresses ageing & life extension (degradation & deterioration) management processes Audit findings reviewed by senior management Management improvements identified SCE verification process addresses ageing & life extension (degradation & deterioration) issues Supplementary Questions: The duty holder shall demonstrate that a process is in place to review findings and to implement continuous improvement with respect to well envelope plant and equipment ageing & degradation. E-1. What is the frequency and scope of audits of the well integrity management system, including degradation & deterioration issues? E-2. Who performs the well integrity management system and well degradation & deterioration audits? Internal or third-party? E-3. How frequently is the well integrity management system, including degradation & deterioration strategies reviewed and up-dated? E-4. How are recommendations to senior management made with respect to the level of resources required to maintain integrity? E-5. How are observations on the effectiveness of the well integrity management system reported to senior management? E-6. How does the duty holder analyse and report information relating to lost production, incidents, failures, etc? E-7. What methods are used to indicate trends or issues in the condition of the plant and equipment? E-8. Is there evidence available of lessons learned and trends of incident, accident and nearmiss data being used to improve and the well integrity management system? E-9. Is there evidence available of manager’s (including senior managers) being aware of the status and condition of the well envelope plant and equipment? The duty holder shall produce a 'statement of well integrity' as produced by the technical authorities for senior management. E-10. Who is on the distribution list for the 'statement of well integrity'? September 2011 V1.0 Page 14 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section E: Ageing & Life Extension - Auditing and Reviewing Performance E-11. Are the duty holder's managers and senior managers involved with the well integrity management system, including degradation & deterioration audit process? E-12. Are the changes recorded/logged assessed, and approved before the changes are implemented? The duty holder shall demonstrate that the verification process addresses adequately the potential loss of integrity arising from degradation & deterioration of Wells. E-13. What reference is made in the corporate verification scheme to ageing and life extension (degradation & deterioration) of Wells? E-14. Are performance standards on the loss of integrity from degradation & deterioration available for all safety critical elements (SCE)? E-15. To what extent has the verification process identified any deterioration from ageing mechanisms and associated loss of integrity or demonstrated that integrity has not been compromised by ageing mechanisms? E-16. What improvements have been identified and implemented as a result of the verification process? E-17. How has the senior management satisfied itself that the verification process has addressed adequately the loss of integrity associated with degradation & deterioration of the well envelope? E-18. What conclusions can be drawn directly from the verification process on the risks from ageing and life extension (degradation & deterioration) of wells to the overall integrity of the installation? September 2011 V1.0 Page 15 of 16 KP4: Ageing and Life Extension - Inspection Template - Wells Section E: Ageing & Life Extension - Auditing and Reviewing Performance Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NON-COMPLIANCE SIGNIFICANT NONCOMPLIANCE GENERAL NON-COMPLIANCE PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Court proceedings recommended 6 Enforcement Notice Served Letter & changes made to intervention 4 Letter Verbal advice No findings 3 2 1 5 September 2011 V1.0 NOT INSPECTED 0 Page 16 of 16