AUSTRALIA ARGENTINA CANADA EGYPT NORTH SEA U.S. CENTRAL U.S. GULF. SEMS HAZARD ANALYSIS TRAINING September 29, 2011

Transcription

1 AUSTRALIA ARGENTINA CANADA EGYPT NORTH SEA U.S. CENTRAL U.S. GULF SEMS HAZARD ANALYSIS TRAINING September 29, 2011

2 Purpose The purpose of this meeting is to provide guidelines for determination of hazard analysis requirements within the Management of Change process as required by SEMS regulations. 9/29/2011 2

3 Agenda 1. SEMS Requirements (Subpart S and API RP 75) 2. Hazard Analysis Within the MOC Process 3. Hazard Determination (Review) 4. Hazard Analysis Guidelines 5. Hazard Analysis Checklists and Hazard ID Sheets 6. Other Hazard Analysis Methodologies 7. Hazard Analysis Team 8. Documentation and Recordkeeping 9/29/2011 3

4 30CFR SEMS Hazard Analysis What criteria for hazards analysis must my SEMS program meet? Perform initial analysis on all facilities by November 15, 2011 Update the analysis at regular intervals (5 or 10 years, depending on complexity and risk level) Review the current hazard analysis whenever there is a change to the facility and update as necessary (continuous hazard analysis revalidation) Update the analysis when an internal audit is conducted to ensure that it is consistent with current operations on the facility. Document and maintain current analysis for each operation for the life of the operation at the facility. 9/29/2011 4

5 30CFR SEMS Hazard Analysis The hazards analysis must address the following: Hazards of the operation; Previous incidents related to the operation you are evaluating, including any incident in which you were issued an Incident of Noncompliance or a civil or criminal penalty; Control technology applicable to the operation your hazards analysis is evaluating; and A qualitative evaluation of the possible safety and health effects on employees, and potential impacts to the human and marine environments, which may result if the control technology fails. Must consider human factors You should assure that the recommendations in the hazards analysis are resolved and that the resolution is documented. 9/29/2011 5

6 MOC Hazard Analysis Apache shall provide for updating facility hazard analysis within the Management of Change process to verify that the most recent hazards analysis reflects the current process. Office / Engineering initiated MOCs - Initiator shall make a determination of whether the change requires a modification to the facility hazard analysis Field initiated MOCs Regulatory Foremen shall make determination for hazard analysis requirement 9/29/2011 6

7 MOC Hazard Review All MOCs will include a Hazard Review. This is a determination of the need for additional hazard analysis based on the proposed change and review of the current facility hazard analysis. The experience gained by industry in the design and operation of offshore structures has been compiled in a series of standard procedures, recommended practices, company standards, and regulatory requirements that represent good practice. These documents incorporate the lessons learned from previous designs and hazard analysis, and accident and incident investigations. These standard practices have a built-in hazards analysis since the inherent hazards have already been identified and the standard methods for control of the hazards have been defined. 9/29/2011 7

8 MOC Hazard Review A high level of safety can be achieved by checking for compliance with standard practices in design, construction, operation and maintenance. Once a process has been thoroughly evaluated, the hazards are identified, and the controls are defined. Then subsequent similar processes can be analyzed by checking that the standard controls are installed. (Hazard ID sheets) A good example of safety through standard practice is given by API RP 14C. This document was prepared by first analyzing the basic hazards inherent in production facilities and defining the standard measures to control the hazards. 9/29/2011 8

9 Do NOT Need Hazard Analysis 1. Routine operation / change (covered by operating procedures, safe work practices, etc.) 2. Replacement in Kind (May or may not require MOC) o o o Designed / operated / maintained per current industry codes, practices, standards (API RP 14C, ASME Section VIII Pressure Vessel Code, etc.) Meets all current regulations (BOEMRE, Coast Guard, etc.) AND no other interface issues with existing facility. Example: new separator using existing tie-ins, safety devices per 14C no hazard analysis required; additional separator with new tie-ins hazard analysis required. 9/29/2011 9

10 Construction MOCs Construction - Engineering New Facility, Pipeline or Structure Facility, Pipeline or Structural Modification (unless meets exemptions) Construction Mechanical Integrity Facility, Pipeline or Structural Modification (unless meets exemptions) X Maintenance (unless bypassing is required that is not covered in operating procedures, safe work practices, etc.) 9/29/

11 Well Work / Drilling MOCs Drilling New Drill, P&A, TA, Tieback or Side Track Production Engineering New Completion, Recompletion or Workover Wire Line / Electric Line 9/29/

12 Decommissioning Decommissioning Pipeline Abandonment Platform Removal Well TA or P&A 9/29/

13 Personnel MOCs X Contract Company Change X Elimination of Personnel X Merger/Acquisition X Substitution of Personnel Depends on personnel roles/responsibilities as defined in operating procedures, emergency response, safe work practices. Elimination of a position would be an instance where a hazard analysis is required to determine whether this will affect the safe operation of a facility. (May need to develop a Hazard ID sheet for this.) 9/29/

14 API 14J Recommendations Concentrate on the areas that present the greatest risk. Low risk facilities, such as unmanned wellhead platforms with minimal processing equipment, the review shall concentrate on verification that the facility will shut-in upon detection of unsafe conditions. Moderate risk facilities, such as unmanned production and processing platforms, the review shall additionally concentrate on mitigation of an accidental release. This shall include fire and gas detection/protection and ignition prevention. Highest risk facilities, such as production or processing platforms with living quarters, the review shall additionally concentrate on the effects of an uncontrolled release on personnel. This shall include layout, fire or explosion effects, escape and rescue, and emergency response. 9/29/

15 Hazard Analysis Guidelines Hazard analysis must be appropriate to the complexity of the operation and must identify, evaluate and manage the hazards involved in the operation. Analysis must use orderly, systematic methodology appropriate to the risks of the facility. API 14J based checklists Hazard ID sheets 9/29/

16 Questions to Ask Understanding the risk associated with an activity requires answering the following questions: What can go wrong? (Does this change present opportunities for harm to personnel, environment, equipment, reputation, financial?) How bad could it be? (ALARP: What else can we reasonably do to reduce the risk of the hazard occurring or lessen the severity if it occurs?) How often might it happen? (Do we have or do we plan to have safeguards in place to prevent or minimize the likelihood that the hazard will occur?) 9/29/

17 Offshore General Hazards Generally concerns: air / water pollution, fire / explosion, personnel injury. 1. Loss of containment / uncontrollable releases 2. Proximity of ignition sources to fuel sources 3. Providing for personnel protection and escape. 4. Spatial limitations (living quarters location, flammable / hazardous inventory) 5. Severe environment (corrosion, isolation, weather) 6. High pressure / high temperature (normal & abnormal conditions) 7. Rotating equipment 9/29/

18 Some Things to Consider Previous experience with a similar facility or operation Unusual / unique location, design, equipment arrangement or emergency response considerations Any findings that need to be brought to resolution before startup or that require immediate attention should be clearly identified Operating procedures and practices, including SIMOPS guidelines Are procedures in place for protection and evacuation of personnel during all phases of the change (installation, startup, operation, shutdown?) Does the change introduce a new or unusual hazard (temporary or permanent) that could cause harm to personnel or the environment? 9/29/

19 Reasons for Hazard Analysis Change in facilities may include mechanical changes that would not necessarily appear on a process flow diagram, including drilling and construction equipment and temporary connections or replaced components that are not in kind, such as: Replacement equipment or machinery that differs in specifications from the original equipment or previously approved modification. Temporary piping, connections, pipe repairs, or hoses. Temporary electrical equipment or utility connections, other than for emergency situations. Modifications to drilling diverter system that have not been previously approved. Modifications to blowout preventers (BOPs) that have not been previously approved. Modifications to drilling top drives that have not been previously approved. 9/29/

20 Reasons to Update Hazard Analysis 1. A new job, task or activity is introduced. 2. Current standard operating procedures need to be altered. 3. New equipment or machine will be installed. 4. New (different) safety equipment is introduced. 5. Chemical or fuel replacement. 6. After an incident or accident occurrence. 7. Simultaneous operations (SIMOPS) on the facility if not covered by operating procedures or safe work practices. 8. As a result of safety audit or inspection. 9/29/

21 Reasons to Update Hazard Analysis 9. New facility projects that involve production or process tie-ins to existing facilities, equipment reconfiguration, or modification of existing facilities/equipment. 10. Modification of existing facilities that may require evaluation of structure or supports. 11. Projects to increase facility throughput or accommodate different produced fluids which are outside the original design parameters. 12. Significant changes in operating conditions, including pressures, temperatures, flow rates, or process conditions different from those in the original process or mechanical design. 13. Changes in alarms, instrumentation, and control schemes. 9/29/

22 Reasons to Update Hazard Analysis 14. Modifications of the process or equipment that cause changes in the facility s pressure relief requirements. 15. Adding bypass connections around equipment. 16. Operations outside the scope of current written operating procedures. 17. Introduction of new or different process, permanent or temporary. 9/29/

23 Hazard Analysis Aids DEVELOPED: Low Risk Facility Checklist Shut-In Facility Checklist Medium High Risk Facility Checklist (From API 14J) IN DEVELOPMENT: Equipment - Specific Checklists / Reference Sheets Operation Specific Checklists / Reference Sheets(Wellwork, etc.) Personnel Replacement? 9/29/

24 Other Hazard Analysis Methods Other hazard analysis methodologies (HAZOP, What-If, or Fault Tree, FMEA) should generally be limited to analyzing the following areas: New facility New process or equipment no previous experience Equipment or process requiring high reliability Complex control systems New toxic material processes Unusually high risk to personnel or environment 9/29/

25 Hazard Analysis Team Persons knowledgeable in engineering, operations, design, process, safety, environmental and other specialties as appropriate Person(s) with experience in the operations being evaluated At least one person proficient in hazards analysis methodologies being employed If only one person performs the hazard analysis, that person should not have participated in the original design of or modifications to the facility. 9/29/

26 Documentation A written (electronic) hazard analysis report shall be prepared that will: Identify the hazard analysis procedure utilized (API 14J Checklist, Hazard ID, etc.) Identify the potential hazards Discuss consequences of hazardous condition and existing safeguards in place Include recommendations for additional safeguards, alternatives or corrective actions as may be necessary for risk mitigation. Communicate the findings and to appropriate personnel. Include names of participants and date(s) of review. This analysis shall be maintained throughout the life of a facility to provide the basis for future modifications and hazard analysis. 9/29/