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– Production Installation
Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] WELL ENGINEERING & OPERATIONS SAFETY CASE ASSESSMENT TEMPLATE – PRODUCTION INSTALLATION Work Instructions Topic specialists should use this template to record their assessment of the Well Engineering and Operations aspects of a safety case. Assessment should be against the requirements of SCR2015. Exemplar Approach - This template should be used in accordance with the scope of the Assessment Instructions when the topic is included for assessment. An exemplar approach may be sufficient if some material has been previously accepted and has not materially changed. For example a CMAPP or SEMS from an existing, accepted safety case. The template is one of a series covering all assessment topics, which together form a complete record of the safety case assessment and create evidence of how the decision to accept the case, or not, was reached. The templates identify the specific regulatory requirements of SCR2015 for the topic and indicate what the competent authority expects to find within a safety case to demonstrate that those requirements are met. The template complements the published guidance that supports the regulations and topic sector guidance. The templates are available to promote transparency and assist duty holders in drafting submissions. Green text indicates regulatory requirements that are new in SCR2015. Black text represents regulatory requirements that are contained in both SCR2005 and SCR2015. Non Acceptance Issue - A Non Acceptance Issue (NAI) is a deficiency in the demonstration made within a safety case, which, if not resolved, will prevent the case from being accepted under the relevant statutory provisions. Non Acceptance Issues must be sent by a formal letter to the duty holder requiring them to be dealt with in the appropriate manner, giving the duty holder a clear understanding of how to address the deficiency. Clarification - A Clarification is an explanation provided by a duty holder on request during assessment to enable the assessing Inspectors to be confident of their interpretation of the information in a safety case. Clarifications are a routine part of assessment work and should be raised with a duty holder promptly. Clarifications do not require formal letters. Communicating by telephone and email is sufficient. A meeting between the duty holder and relevant topic specialists may also be appropriate in some circumstances for clarifications. Clarification is not a first stage before raising non-acceptance issues. Any aspect that could credibly lead to a Non-Acceptance Issue should be raised as such in the first instance. TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 1 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Relevant Pre-Existing Guidance APOSC Principles: Principle 1 The factual information should meet the SCR2015 requirements and provide sufficient detail to support the arguments made in the case Management of health and safety Principle 2 The safety case should demonstrate that the management system is adequate to ensure compliance with the relevant statutory provisions… Principle 3 The management system should show an appropriate level of control during each phase of the installation life cycle, including design, construction, commissioning, operation, decommissioning and dismantlement Major accident hazard identification Principle 4 A systematic process should be used to identify all reasonably foreseeable major accident hazards that apply to the installation, together with potential initiating events or sequences of events Major accident risk evaluation Principle 5 The methodology and evaluation criteria adopted for major accident risk assessment should be clear Principle 6 Any criteria for eliminating the less significant risks from detailed consideration in the major accident risk evaluation should be explained Principle 7 The assessment should take account of people exposed to exceptional risks Principle 8 The major accident risk evaluation should take account of human factors TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 2 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Principle 9 Conclusions reached in risk assessment processes should take uncertainty into account Principle 10 The identification of risk reduction measures should be systematic and take into account new knowledge Principle 11 The reasoning behind the choice of risk reduction measures to be implemented should be described. Decisions on implementation should take reasonable practicability into account Principle 12 Risk reduction measures identified, as part of the risk assessment, should be implemented if they are reasonably practicable Principle 13 In deciding what is reasonably practicable, the case should show how relevant good practice and judgement based on sound engineering, management and human factors principles have been taken into account Principle 14 Where remedial measures are proposed to reduce risk, the timescale for implementing them should take account of the extent of such risks and any practical issues involved Major accident risk management Principle 15 Measures taken to manage major accident hazards should be described Principle 16 The safety case should explain how inherently safer design concepts have been applied in the design decisions taken Principle 17 The measures for preventing major accident hazards should take account of the various activities undertaken during the installation's current phase of operation Principle 18 Appropriate detection measures should be provided for any reasonably foreseeable event requiring an emergency response TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 3 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Principle 19 Appropriate control and mitigation measures should be provided to protect personnel from the consequences of a major accident Principle 20 Arrangements for controlling an emergency should take account of likely conditions during emergency scenarios Emergency response Principle 24 Evacuation and escape arrangements should be integrated in a logical and systematic manner, taking account of the environment in which they may need to function Combined operations Principle 28 The management system should address the additional risks associated with combined operations Principle 29 A systematic approach should be taken to assessing the impact of combined operations on the conclusions of the operational safety case for each installation Principle 30 A systematic approach should be taken to identifying and assessing any additional major accident hazards arising from combined operations. These can be new hazards or changes to existing hazards Principle 31 The measures for emergency response should be appropriate to the particular combined operation GASCET Chapters: 2.4.1 Wells risk evaluation and management This Section provides guidance for the assessment of safety case content with respect to wells and well systems, from hazard identification through to consequence determination, including risk management measures. TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 4 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Other Guidance Reference: The following documents are industry guidance that can aid in determining if the duty holder is following good industry practice: Well Lifecycle Practices Forum Guidelines for the suspension and abandonment of wells Guidelines on qualification of materials for the suspension and abandonment of wells Guidelines for well-operators on competency of well-examiners Guidelines for well-operators on well examination Guidelines on competency for wells personnel Guidelines on relief well planning for offshore wells Well life cycle integrity guidelines Guidelines on BOP Systems for Offshore Wells Energy Institute Model code of safe practice Part 17 Vol 1,2 & 3 – High Pressure High Temperature Wells Model code of safe practice Part 15 – Area classification code for installations handling flammable fluids Guidelines for offshore oil and gas installations that are not permanently manned TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 5 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] 1. Safety case for production installation requirements a) SCR2015 Schedule 6 – Particulars to be included in a safety case for the operation of a production installation TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 NAI Clarification SCR2015 Regulatory Requirement 1. The name and address of the operator of the installation. 2. The maximum number of persons— (a) expected to be on the installation at any time; (b) that may, in normal operating conditions and within design constraints, be on the installation at any time; and (c) for whom accommodation is to be provided. 5. An adequate description of the operator’s safety and environmental management system, including information from it that is relevant to the production installation. 7. A description of the extent to which the operator has taken into account any matters raised by the competent authority pursuant to regulations 15(2) or 19(2). 8. A description of the main requirements in the specification for the design of the installation and its plant, which must include— (a) any limits for safe operation or use specified therein; (c) a description of how the duty holder has ensured, or will ensure, the suitability of the safety and environmental-critical elements; (e) any relevant codes, standards and guidance used in the construction and commissioning of the installation. 10. A suitable plan of the location of the installation and of anything connected to it, and particulars of— 11. A description, with suitable diagrams, of the installation, including a description of— (a) the main and secondary structure of the installation and its materials; (b) its plant; (c) the layout and configuration of its plant; (e) any well connected or to be connected to the installation. 12. Particulars of the types of operation, and activities in connection with an operation, including both those— (a) which the installation is capable of performing; and (b) which are to be carried out. 13. Particulars of the plant and arrangements for— (a) the control of any well operations, including those— (i) to control pressure in a well; (ii) to prevent the uncontrolled release of hazardous substances; and (iii) to minimise the effects of damage to subsea equipment by drilling equipment; (b) process safety; (c) the containment of hazardous substances (not already addressed under subparagraph (a)(ii)); (d) the prevention of fire and explosion; and Page 6 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] 15. A description of how the operator has ensured, or will ensure, compliance with regulation 4(1) of the PFEER Regulations. 18. A description of the plant used and arrangements made for protecting persons on the installation from hazardous substances, including toxic gas, at all times. 19. A description of the measures taken or to be taken or the arrangements made or to be made for the protection of persons on the installation from hazards, including explosion, fire, heat, smoke, toxic gas or fumes in particular during any period while they may need to remain on the installation following an incident which is beyond immediate control and for enabling such persons to be evacuated or rescued from the installation where necessary, including provision for— (a) temporary refuge; (b) routes from locations where persons may be present to temporary refuge and for egress therefrom to points from where the installation may be evacuated; (c) means of evacuation at those points; and (d) facilities within temporary refuge for the monitoring and control of the incident and for organising evacuation. 20. Arrangements for the maintenance of control systems to prevent damage to the installation and the environment in the event that all personnel are evacuated. 21. The description of the internal emergency response arrangements. 23. Particulars of any combined operations which may involve the installation, including— (a) a summary of the arrangements in place for co-ordinating the management systems of all duty holders involved in any such combined operation; (b) a summary of the arrangements in place for a joint review of the safety aspects of any such combined operation by all duty holders involved, which must include the identification of hazards with the potential to cause a major accident and the assessment of risks which may arise during any such combined operation; (c) the plant likely to be used during any such combined operation; and (d) the likely impact any such combined operation may have on the installations involved. 24. Any other relevant details. Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments Para 1 - Does the safety case have the name and address of the operator of the installation? If applicable has a separate Well Operator been identified? (APOSC Principle 1) Para 2(a), (b) & (c) - Does the safety case identify who shall be aboard during well operations? Well operations can include: well construction, intervention, workover and abandonments. (APOSC Principle 1 & 2) Para 5 - Does the safety case have an adequate description of the operator’s safety and environmental management system, with respect to well operations? Does it contain details of the following? - TRIM: 2015/273820 Manning philosophy for well operations Revised: 22 July 2015 Owner: ED 4.4 Page 7 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] - Well operations organisation Health and safety policy in well operations Competency / training in well operations Selection and control of well operations contractors (APOSC Principle 2) Para 7 - Has the operator included a description of the extent to which it has taken into account any matters raised by the CA as part of the inspection of the design notification for well operations? (APOSC Principle 1) Para 8(a) – Does the safety case detail safe operating limits for the wells and the equipment used to conduct well operations? Para 8(e) – Are the relevant codes, standards and guidance used in the construction and commissioning of the equipment used in well operations detailed in the safety case? (APOSC Principle 1) Para 10 – Does the safety case contain a suitable plan of the installation showing what wells are connected to it? (APOSC Principle 1) Para 11(a)(b)(c) & (e) - Does the safety case contain descriptions with suitable diagrams of the wells and equipment used in well operations? Does it contain the following? - Installation and subsea wells Rig power systems Drilling equipment Fluid handling equipment Temporary production test equipment Gas handling facilities Derrick / rig floor Well operations lifting equipment Well bay area Installation hazardous areas Well schematic / description Completion diagrams Wellhead / xmas trees Reservoir conditions Reservoir fluid properties Intermediate formations Shallow formations Drilling problem history / experience (APOSC Principle 1) TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 8 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Para 12(a) & (b) - Does the safety case contain details of what type of well operations the installation is capable of performing and also those that are to be carried out? i.e. drilling and completion operations scheduled or anticipated; well workover and well servicing operations anticipated. (APOSC Principle 17) Para 13(a)(i)(ii)(iii) - Does the safety case contain particulars of the plant and arrangements used for the control of any well operations, including the control of the pressure in the well, to prevent the uncontrolled release of hazardous substances; and to minimise the effects of damage to subsea wells by drilling equipment. Does it contain details of the following? Well pressure control equipment Well shut-in systems Protection against dropped / swinging load Subsea protection systems (APOSC Principle 19) Para 13(b) – Does the safety case contain particulars of the plant and arrangements used for well related process safety? Does it contain details of the following? Details of the well operations MAH, and identified mitigation measures for them. Shallow gas identification evaluation Shallow gas procedures Identification and evaluation of geological hazards and uncertainties, including temperatures, pore and fracture gradient pressure (APOSC Principles 4,5,6,7,8,9,10,11,12,13 &14) Para 13(c) – Does the safety case require to contain particulars of the plant and arrangements used for the containment of hazardous substances (not already addressed under subparagraph (a)(ii)) (APOSC Principles 4,5,6,7,8,9,10,11,12,13 &14) Para 13(d) – Does the safety case contain particulars of the plant and arrangements used for the prevention of well operations related fire and explosion? Does it contain details of the following? Well operations procedures / policies Well pressure control policy TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 9 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] - Well directional control policy Annulus monitoring policy Well integrity management arrangements Casing, completion, wellhead and xmas tree design (APOSC Principles 15 & 16) Para 15 – What arrangements are in place for controlling a well related emergency. What are the roles and responsibilities during well control incidents? Para 21 - How are well operation emergency situations included in the internal emergency response arrangements. (APOSC Principle 20) Para 18 - Does the safety case contain a description of the plant used and arrangements made for protecting persons on the installation from hazardous substances, including toxic gas at all times? Does it contain details of the following? Well operations fire, gas and hydrogen sulphide detection. (APOSC Principle 18) Para 19(b) – Does the safety case provide details of the escape routes from well operations areas? Para 19(d) – Does the safety case provide details of how the wells can be monitored and controlled (including wells with active well operations underway on them) in the event of an emergency? (APOSC Principle 24) Para 20 - Does the safety case provide details of the arrangements for the maintenance of well control (BOP’s and online wells) systems, to prevent damage to the installation and environment in the event that all personnel are evacuated? If applicable, does the safety case provide information on the arrangements of how wells will be closed in remotely in the event that the installation has been evacuated? (APOSC Principle 20) Para 23(a)(b)(c) & (d) – Does the safety case contain particulars of any combined operations which may involve the installation. Does it contain details of the following? Does it detail how the arrangements for the management systems of all duty holders TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 10 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] - - - involved in the combined operations will be co-ordinated. Does it summarise the arrangements for a joint review of the safety aspects of any such combined operation by all duty holders involved, which must include the identification of hazards with the potential to cause a major accident and the assessment of risks which may arise during any such combined operation A simultaneous operations (SIMOPS) matrix the plant likely to be used during any such combined operation, such as an integrated production emergency shut-down (ESD) system. the likely impact any such combined operation may have on the installations involved (APOSC Principles 28,29,30 & 31) Para 24 – Any other relevant details put forward by the duty holder. (APOSC Principal not applicable) b) SCR2015 Reg 13 - Description of well examination scheme SCR2015 Regulatory Requirement 13 - (2) For the purpose of regulation 8(7), a description of the well examination scheme complies with this paragraph if it includes— (i) so far as is reasonably practicable, there can be no unplanned escape of fluids from the well; and (ii) risks to the health and safety of persons from it or anything in it, or in strata to which it is connected, are as low as is reasonably practicable; and NAI (b) a description of the means of verifying that the well is designed and constructed, and is maintained in such repair and condition, that— Clarification (a) a description of the criteria for selection of the well examiner to carry out functions under the scheme; (c) details of the arrangements to carry out the functions under the scheme including— (i) the examination of the well, or a similar well, by the well examiner; (ii) the examination of information required under regulation 11(2)(a)(ii); TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 11 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] (iii) the examination of work in progress; (iv) the taking of remedial action by the well operator; (v) the reporting of any instances of non-compliance of the well operator with the standards of the scheme; and (vi) the review of the scheme. Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments Para 13(2)(a) - Does the well examination scheme description include the criteria for selecting a well examiner to carry out the required functions? Para 13(2)(b) - Does the description include the verification process for the well design, construction, maintenance and repair and condition that(i) sfairp there can be no unplanned escape of fluids and (ii) the risks to the health and safety of persons from it or anything in it, or in strata to which it is connected are alarp Para 13(2)(c) - Is there details of the arrangements’ to carry out the functions including – (i) the examination of the well, or a similar well, by the well examiner; (ii) the examination of information required under regulation 11(2)(a)(ii); (iii) the examination of work in progress; (iv) the taking of remedial action by the well operator; (v) the reporting of any instances of non-compliance of the well operator with the standards of the scheme; and (vi) the review of the scheme. TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 12 of 13 Document Title: Well Engineering & Operations Safety Case Assessment Template – Production Installation Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] WELL ENGINEERING AND OPERATIONS REQUIREMENTS - ASSESSMENT SUMMARY NAI – Non Acceptance Issue SCR2015 Regulatory Requirement Clarification Required NAI Required Conclusion 1. Production Installation Safety Case Requirements a) Schedule 6 – Particulars to be included in a safety case for the operation of a production installation b) c) 2. Well Examination Scheme Requirements a) Regulation 13(2) – Description of verification scheme and well examination scheme b) TRIM: 2015/273820 Revised: 22 July 2015 Owner: ED 4.4 Page 13 of 13