COMMITTEE FOR PREPARING STANDARD ON COMBINED OPERATIONS

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2 FOREWORD The Oil Industry in India is more than 100 years old. Because of various collaboration agreements, a variety of international codes, standards and practices have been in vogue. Standardisation in design philosophies and operation and maintenance practices at a national level was hardly in existence. This coupled with feed back from some serious accident that occurred in the recent past in India and abroad, emphasised the need for the industry to review the existing state of the art in designing, operating and maintaining oil and gas installations. With this in view, the Ministry of Petroleum and Natural Gas in 1986 constituted a Safety Council assisted by the Oil Industry Safety Directorate (OISD) staffed from within the industry for formulating and implementing a series of self regulatory measures aimed at removing obsolescence, standardising and upgrading the existing standards to ensure safe operations. Accordingly, OISD constituted a number of functional committees of experts nominated from the industry to draw up standards and guidelines on various subjects. The present guidelines, earlier titled Standard on Combined Operations, was published in August, It was taken up for review by the functional committee, constituted for the purpose, in the year The standard has been changed to guidelines and renamed as Simultaneous Operations in Exploration & Production Industry. The document is based on the accumulated knowledge and experience and the various national and international codes and practices. The guidelines are meant to be used as supplement and not as a replacement for existing codes and practices. It is hoped that provisions of this guidelines, if implemented objectively, may go a long way to improve the safety and reduce accidents in Exploration & Production Industry. Users are cautioned that no guidelines can be a substitute for the judgement of responsible and experienced personnel involved in simultaneous operations. Suggestions are invited from the users after it is put into practice to improve the document further. Suggestions for amendments to the document should be addressed to the Coordinator, Committee on Simultaneous Operations in Exploration & Production Industry, Oil Industry Safety Directorate, 7 th Floor, New Delhi House, 27-Barakhamba Road, New Delhi

3 These guidelines in no way, supersedes the statutory requirements of bodies like DGMS, PESO or any other Government Body which must be followed as applicable. (i) COMMITTEE FOR PREPARING STANDARD ON COMBINED OPERATIONS Name Organisation Position in Committee Shri J.T. Mahavar ONGC Leader 2. Shri A.B. Chakraborty ONGC Member 3. Shri D. Kumar OIL Member 4. Shri R.G. Goel ONGC Member 5. Shri P.K. Jain ONGC Member 6. Shri T.Singh OISD Coordinator

4 (ii) COMMITTEE FOR REVIEW OF GUIDELINES ON SIMULTANEOUS OPERATIONS IN EXPLORATION & PRODUCTION INDUSTRY Name Organisation Position in Committee Shri Rajesh Kakkar ONGC Leader 2. Shri K.C. Patel ONGC Member 3. Shri Ahmed Javed ONGC Member 4. Shri B.N. Sahoo OIL Member 5. Shri A. Bora OIL Member 6. Shri D.K.Varshney OISD Coordinator (iii)

5 Guidelines on Simultaneous Operations in Exploration & Production Industry Contents S.No. Description Page No 1.0 Introduction Scope Definition Offshore Simultaneous Operations Simultaneous Operations on and around well platform related to jack-up drilling rig (for drilling and workover) Simultaneous Operations on a process platform Non rig related simultaneous activities on a well platform Onshore simultaneous operations Simultaneous Operations involving drilling rig / workover rig Simultaneous Operations inside production installation 21 Annexure-A - Delegation of Authority letter, in case of hired rig 24 Annexure-B - Pre-operations check list (offshore) 25 Annexure-C - Documents / information (offshore) 27 Annexure-D - Platform handover form for drilling / working over 28 Annexure-E - Post-operations check list (offshore) 30 Annexure-F- Simops - sample matrix 31 Annexure-G- Simops checklist (onshore) 32 (iv)

6 1 GUIDELINES ON SIMULTANEOUS OPERATIONS IN EXPLORATION & PRODUCTION INDUSTRY 1.0. INTRODUCTION This document presents the procedures for safe conduct of drilling, workover, production, revamping / construction and other related activities simultaneously from the same well platform / process platform / well site / production installation. The purpose of this document is to specify the limitations under which various operations can be carried out simultaneously such as to ensure the safe conduct of operations. Simultaneous operations should be thoroughly analysed and planned with the objective of limiting additional risk imposed by multiple activities and operations being undertaken at the same place or in the vicinity at the same time as opposed to the risk associated with the execution of these individually. Risk assessment studies should form the basis for deciding upon simultaneous operations SCOPE The guidelines broadly cover the following related to simultaneous operations (SIMOPS) in E&P industry: - Organisation and management structure. - Practices to be followed. - Scenarios for both offshore and onshore DEFINITION 3.1 Cold work: An activity which does not produce sufficient heat to ignite a flammable air - hydrocarbon mixture or a flammable substance. 3.2 Drilling: A process to produce cylindrical hole in earth, called well, using a drilling rig, to access hydrocarbon bearing reservoir. 3.3 Hot work: An activity that can produce a spark or flame or other source of ignition having sufficient energy to cause ignition, where the potential for flammable vapours, and gases exists. 3.4 PPE - Personal Protective Equipment: Devices or clothing used to insulate an individual from the chemical, thermal, explosive, electric shock or other hazards presented by the environment in which one is working. Some of PPEs are Safety goggles, Apron, Safety shoes, Chemical-resistant gloves, helmet etc. 3.5 Process platform / production installation: Facility, in offshore / onshore, where produced fluid is processed (oil / water / gas separation, gas dehydration etc.) before onward transportation. 3.6 Simultaneous operations (SIMOPS): Also called combined operations are those where more than one major activity e.g. drilling, production, workover operation, revamping / construction etc. is undertaken at the same place or in the

7 2 vicinity along-with activities such as material handling and hot work in an environment where oil / gas is present or produced nearby. 3.7 Station bill: A written list posted in the crew s quarters and other conspicuous places, listing the station of the crew. 3.8 Workover: It involves any well maintenance / repair job, water shut off job, installation / repair of artificial lift /changing of production zone etc by using workover / drilling rig. The term includes any associated cold work. 3.9 Xmas tree: An assembly of valves and fittings in upper part of well, to control flow of fluids from the well. 4.0 OFFSHORE SIMULTANEOUS OPERATIONS Typical scenarios covered under offshore are: Simultaneous activities on and around well platform related to a) Jack-up drilling rig and production operations, and b) Jack-up drilling rig and revamping / construction. Simultaneous activities on a process platform related to Production operations, revamping / construction and marine operations. Non- rig related simultaneous activities on a well platform The above scenarios are indicative only. The companies should develop their own scenarios based on the risk assessment of various SIMOPS activities. 4.1 Simultaneous operations on and around well platform related to jack-up drilling rig (for drilling and workover) SIMOPS Organisation and management: When the drilling rig / workover rig is operating over the well platform, both the facilities should be defined and considered as a single combined installation. During the period of time, the offshore drilling rig is adjacent to the well platform, then for safety aspects such as fire suppression system, mustering, works permits, etc., the well platform should be considered as an extension to the drilling rig. However, the production representative should be deputed by the concerned offshore installation manager (OIM) of the process complex, on need basis, to monitor production well systems on the well platform. For various SIMOPS, document should be prepared by the company outlining all the dos and don t s, special safety precautions to be taken, roles and responsibilities of key personnel, operations which have to be stopped / can be continued / can be continued with prior approval (at appropriate level), emergency response plan, etc.

8 3 The person responsible for SIMOPS should be the custodian of SIMOPS document and it is the responsibility of the custodian to seek agreement or approval from appropriate authority for any amendment Responsibilities In case of hired rig The responsibilities as enumerated below are also applicable to company owned rigs operating under operation and maintenance / man management contract. Company man The Company representative on board the rig, has the overall responsibility for SIMOPS. Controls and regulates the work of the drilling / well intervention programmes on the combined installation. Is authorised as per Annexure-A, by the company as overall responsible for SIMOPS on the combined installation. Rig OIM Is responsible for the safety of personnel and equipment on board the rig and performs work programme approved by the company management. Offshore Installation Manager (OIM) Any operation in the operating field should be with the knowledge of the offshore installation manager (OIM). Liaises with the company man and production representative for all operational matters related to SIMOPS and also co-ordinates the shut down requirements of the wells. Production Representative (Wellhead Manager) The representative of the production department (of the company) on the combined installation, ensures that all production operations on the installation are carried out in the accepted and safe manner at site. Works closely with rig OIM and company man as part of the onsite SIMOPS team and advises the company man of any operations / practices which could be hazardous or are in violation of the approved SIMOPS procedures. Also liaises with well services representative. Engineering and Construction Representative Responsible for revamping / construction activities, liaises with company man and production representative for day to day activities related to revamping / construction and works closely with them to ensure adherence to SIMOPS procedures. Obtains necessary work permit and clearance from company man and production representative before commencing revamping / construction activities. Contractor Representative The onsite representative of contractor engaged for revamping / construction activities, follows the directions of the engineering and construction representative. Ensures that the contractor s personnel carry out tasks in a safe manner in accordance with SIMOPS procedures and conditions laid out in work permit. Also ensures that the contractor s personnel have been imparted mandatory HSE trainings before being deployed for the job at site, and that they use PPE while on the job.

9 In case of company owned rig Rig OIM Has the overall responsibility for SIMOPS. Is responsible for the safety of personnel and equipment on board the rig and performs work programme approved by the company management. Offshore installation manager (OIM) Any operation in the operating field should be with the knowledge of the concerned offshore installation manager (OIM). Liaises with rig OIM and production representative for all operational matters related to SIMOPS and also coordinates the shut down requirements of the wells. Production Representative (Wellhead Manager) The representative of the production department on the combined installation, ensures that all production operations on the installation are carried out in the accepted and safe manner at site. Works closely with rig OIM as part of the onsite SIMOPS team and advises the rig OIM of any operations / practices which could be hazardous or are in violation of the approved SIMOPS procedures. Also liaises with well services representative. Engineering and Construction Representative Responsible for revamping / construction activities, liaises with rig OIM and production representative for day to day activities related to revamping / construction and works closely with them to ensure adherence to SIMOPS procedures. Obtains necessary work permit and clearance from rig OIM and production representative before commencing revamping / construction activities. Contractor representative The onsite representative of contractor engaged for revamping / construction activities, follows the directions of the engineering and construction representative. Ensures that the contractor s personnel carry out tasks in a safe manner in accordance with SIMOPS procedures and conditions laid out in work permit. Also ensures that the contractor s personnel have been imparted mandatory HSE trainings before being deployed for the job at site, and that they use PPE while on the job Basic Procedures to be followed during SIMOPS (a) SIMOPS Programme Prior to the drilling rig moving to a new well platform location, a meeting of the drilling, production and HSE representative should be held to agree and confirm the programme and preparatory activities. Prior to undertaking SIMOPS, job safety analysis should be carried out by the person responsible for SIMOPS (company man / rig OIM, as the case may be) with all agencies associated with SIMOPS, to ensure that all the hazards related to the proposed operations are identified, assessed and determined to have the risk as low as reasonably practicable. Job analysis report should be approved by offshore installation manager (OIM).

10 5 (b) Well Closure Prior to the Drilling Rig moving onto the production well platform, a deep set barrier (plug) should be set in the existing well completions or subsurface safety valve should be closed. Also, wing valve to be closed. Normal production can be resumed after the rig is jacked up to the required air-gap and cantilevered out over the wellhead. (c) Well Platform Control The telemetry control system for the well platform should remain operational. (d) Hazardous Areas Hazardous area classification for well platform and the rig s hazardous area classification should be combined to establish a composite hazardous area classification for the combined installation. (e) ESD Interfaces Well platform ESD system should be extended to the jack-up via an interface box. An interface box with ESD Button should be located at least at each of the following locations on the rig using the same system gas used presently for instrumentation;- Driller s console on Drill Floor Near Tool pusher office In the event of an emergency on the well platform or rig, the manual ESD buttons should be operated. On evaluation of the audibility of hooter of the rig, at the well platform, extension of the same should be provided on the well platform, if necessary. Persons working on rig should be trained in use of ESD systems, during rig induction for SIMOPS. (f) Well Platform Gas Venting Required venting from the lubricators should be controlled by permit to work (PTW) system. A gas detector should be installed below the cantilever to monitor the venting gas. (g) Fire Water System In order to fight any fires on the well platform, which does not have fire water line provision, the rig should install an adequate size sea water line from the rig to the well platform. It should be kept pressurised with adequate pressure in readiness to fight fires. Fire fighting hoses and nozzles should be strategically positioned, and regularly tested, by the production representative. (h) Communication and Coordination Appropriate interfacing and good communication is required between the well platform personnel and drilling rig crew throughout the simultaneous activities. A prestart meeting should be held onboard drilling rig with attendance of senior personnel

11 6 from process platform. The company man / rig OIM, as the case may be, should conduct a daily meeting either in person or over radio / phone with the in-charge of the project activities / offshore installation manager (OIM) / production representative at a mutually convenient time. There must be regular telephonic conversation between offshore installation manager (OIM) and the company man / rig OIM to ensure communication on PTW and work plan. Radio contact should be established between the involved installations and communication channel maintained. (i) Drilling Rig Induction, Station Bill & Mustering The rig should initiate a SIMOPS induction for all personnel when they arrive on the drilling rig. There should be no routine mustering on the well platform. Only in the case of emergency should persons muster on the well platform, in that case they should immediately call the drilling rig control room to inform the muster checker. All the drilling rig station bills and muster points should have a note added to intimate the additional muster point at the well platform. (j) Emergency response In the event of any emergency involving well platform or rig it is the responsibility of the company man / rig OIM, as the case may be, to initiate and co-ordinate all emergency response actions. The primary escape means for the crew on well platform deck should be the rig evacuation means in case the rig is attached to the well platform. The secondary means of evacuation for the well platform based crew should be by mustering at designated muster point on the well platform and launching of life rafts Simultaneous Operations scenarios: Various scenarios under SIMOPS, involving drilling rig and production operations activities on well platform, include: I. During rig approach, piling activity, rig skidding, jack down and pull away from well platform; II. During drilling- with diverter system, regular drilling and H 2 S environment; III. During well completion, well testing and well control; IV. During hot work; V. During helicopter operation. I. During rig approach, piling activity, rig skidding, jack down and pull away from well platform; Moving a jack up rig from and to an oil / gas production well platform is a critical operation due to safety and environmental hazards associated with it. There are number of oil, gas and water injection pipelines around the well platforms. Sea bed survey is to be carried out to protect the pipelines during positioning of the rig. After the sea bed survey, when the jack up rig approaches the well platform for docking, its legs are lowered to touch the seabed and then the rig is pulled / positioned by the towing boats. (i) Prior to rig move to platform, the pre-operations checklist should be signed by the company man / rig OIM, as the case may be, as per Annexure-B, to ensure that all preparatory activities have been completed as per approved SIMOPS.

12 7 (ii) (iii) (iv) (v) (vi) All the documents / information of the platform as shown in Annexure-C, should be handed over to company man / rig OIM, as the case may be, prior to rig move to platform. Complete drawings of pipelines laid within 1000-m radius of the jacket should be available on board of the jack up rig. The pipelines in the vicinity of the well platform are required to be marked with buoys prior to approach of the rig to the well platform. Platform should be handed over by OIM to company man / rig OIM, as the case may be, when the rig is moved to the well platform and when the rig is moved out, the company man / rig OIM, as the case may be, should hand over well platform to OIM as per Annexure-D. All pipelines (oil, gas, and gas injection) of the well platform are required to be isolated from both ends to ensure no ingress of inventory. Information about the pipelines, which are not connected to the jacket but are laid in the close vicinity of the platform should be available with the rig before the rig movement to decide upon the requirement of isolation of any of these lines, depending upon their distance from the likely positions of spud tanks. The underwriters may require the company to provide specific means to monitor the distance between the pipeline and the spud tank continuously either by deploying the divers or by providing transponders and receivers. In order to have good visibility, co-ordination and control of the tugs, the approach to the well platform should be done only during daylight. (vii) Crane operations, supply vessel approach, maintenance of gas and fire detectors, sampling, well acidization and wire-line operation, on the adjacent wells are not to be performed on well platform during movement of jack up rig, piling activity, rig skidding (during rig move), jack down and pull away from well platform. (viii) Adjacent wells should be kept closed during rig approach, rig skidding and pull away. Wells can be kept on production, during piling activity. (ix) The post-operations checklist, as depicted in Annexure-E, should be signed by company man / rig OIM, as the case may be. II. During drilling- with diverter system, regular drilling: and H 2 S environment (i) (ii) (iii) Approach of supply vessel, maintenance of gas and fire detectors, ESD maintenance, well acidization, wire line work on adjacent wells, flow line hook up are not permitted to be performed on well platform during drilling with diverter system where there is medium / high potential of shallow gas. Keeping adjacent wells on production, during drilling with diverter system is to be decided by OIM and company man / rig OIM, as the case may be, on case-tocase basis. During regular drilling, adjacent wells can be kept on production and most of the routine activities on the well platform are permitted. However, based on risk perception, activities like ESD maintenance, well acidizing, line pigging, wire line operations, flow line hook up may require prior approval. Crane operations, approach of supply vessel, maintenance of gas and fire detectors, venting through boom, ESD maintenance, well acidization, wire line work on adjacent wells, flow line hook up are not permitted to be performed on

13 8 well platform during drilling in H 2 S environment. Adjacent wells can be kept on production. III. During well completion, well testing and well control (i) (ii) During installation of Xmas tree, ESD maintenance on well platform is not to be performed. During running of explosives / radio active resources in the hole and during well control activities, operations namely crane operations, sampling / leak test, approach of supply vessel, maintenance of gas and fire detectors, ESD maintenance, well acidization, wire line work on adjacent wells, flow line hookup are not permitted on well platform. Also, all nearby radio communication to be switched off during running of explosives / radio active resources. However, adjacent wells can be kept on production during running of explosives / radioactive sources in the hole. During well control activities, flowing of adjacent wells is to be decided by OIM and company man / rig OIM, as the case may be, on case-to-case basis. IV. During hot work: (i) (ii) When the hot job is planned in the well bay or in vicinity of the wells, wells on production, approach of supply vessel, maintenance of gas and fire detectors, sampling / leak test, ESD maintenance, well acidization are not permitted. However, allowing of crane operation, line pigging, wire lining and flow line hook-up should be decided by OIM and company man / rig OIM, as the case may be. Refer OISD-STD-105 for requirements related to work permit. V. During helicopter operation: During any simultaneous operations, the well platform helideck shall be OUT OF USE. Helicopter contractor should be so informed, and the requisite signs should be positioned on the well platform helideck. All helicopter flights should use rig helideck. Due to the close proximity of the drilling rig, the well platform boat landing should be OUT OF USE during SIMOPS. Use of boat landing of well platform in a restricted manner may be allowed with prior permission from company man / rig OIM, as the case may be. All marine contractors should be so informed. During helicopter operations, well platform related routine activities are allowed. The above scenarios are typical cases. It is recommended that organisation should develop their own SIMOPS matrix, covering all the envisaged activities related to drilling rig and well platform indicating activities which are permitted, which are not permitted and which require prior approval. SIMOPS- sample matrix is given in Annexure F, for reference Various scenarios under SIMOPS, involving drilling rig and revamping / construction activities on well platform, include : I. During rig approach, piling activity, rig skidding, jack down and pull away from well platform; II. During drilling- with diverter system regular drilling and H2S environment; III. During well completion, well testing and well control; IV. During hot work;

14 9 V. During helicopter operation. I. During rig approach, piling activity, rig skidding, jack down and pull away from well platform (i) No revamping / construction related activities like pressure testing, radiography, hot work, confined space entry, scaffolding erection, diving within 100 meters from rig / well platform, working at height, working over side, night operations are permitted on well platform during rig approach and piling activity. (ii) Pressure testing and diving activity within 100 meters from rig / well platform are not permitted during jack down and pull away. Other revamping / construction related activities can be carried out with prior approval of OIM and company man / rig OIM, as the case may be. II. During drilling - with diverter system, regular drilling and H 2 S environment (i) Diving activity within 100 meters from rig / well platform, working at height and night operations are not to be performed when drilling with diverter system where there is potential of shallow gas. (ii) During regular drilling most of the revamping / construction related activities can be carried out. Some of the activities like radiography, hot work on platform, confined space entry, working at heights, night operations may require prior approval of OIM and company man / rig OIM, as the case may be, on case-to-case basis. (iii) During drilling in H 2 S environment, none of the activities related to revamping / construction is to be allowed. III. During well completion, well testing and well control: During running of explosives or radio active sources and during well control activities, no activity related to revamping / construction is to be performed on well platform. IV. During hot work: (i) (ii) During hot work in the well bay or in the vicinity of the wells, the platform wells are to be kept closed. The various activities related to revamping and construction activities on well platform are permitted to be performed with prior approval except pressure testing. Refer OISD-STD-105 for requirements related to work permit. V. During helicopter operation: During helicopter operations, the various activities related to revamping / construction can be performed except diving. For diving, prior permission from company man / rig OIM, as the case may be, should be taken during helicopter operation. As suggested under , organisation should develop their own SIMOPS matrix covering all the envisaged activities. 4.2 Simultaneous operations on a process platform SIMOPS Organisation and management: For various SIMOPS on process platform, document should be prepared by the company outlining all the dos and don t s, special safety precautions to be taken, roles and responsibilities of key personnel, operations which have to be stopped /

15 10 can be continued / can be continued with prior approval (at appropriate level), emergency response plan, etc. The person overall responsible for SIMOPS should be custodian of SIMOPS document and it is the responsibility of the custodian to seek agreement or approval from appropriate authority for any amendment Responsibilities Offshore Installation Manager (OIM) Has the overall responsibility for SIMOPS. Is responsible for the safety of personnel and equipment on the process platform. SIMOPS on a process platform should be in the knowledge of OIM. Process Manager Responsible for SIMOPS related to production activities and marine operations on a process platform. Ensures that all SIMOPS are carried out in a safe manner as per approved SIMOPS procedures. Maintains continuous liaison with OIM regarding SIMOPS. Logistics manager, if stationed on the process platform to deal with the activities related to marine operations, should be responsible for SIMOPS related to marine operations, instead of process manager. Maintenance Manager Responsible for SIMOPS related to revamping / construction activities pertaining to process equipment. Ensures that all SIMOPS are carried out in a safe manner as per approved SIMOPS procedures. Maintains continuous liaison with OIM and engineering and construction representative regarding SIMOPS. Engineering and Construction Representative Responsible for revamping / construction activities, liaises with OIM and process manager / maintenance manager for day to day activities related to revamping / construction and works closely with them to ensure adherence to SIMOPS procedures. Obtains necessary work permit and clearance from OIM / process manager / maintenance manager before commencing revamping / construction activities. Contractor representative The onsite representative of contractor engaged for revamping / construction activities, follows the directions of the engineering and construction representative. Ensures that the contractor s personnel carry out tasks in a safe manner in accordance with SIMOPS procedures and conditions laid out in work permit. Also ensures that the contractor s personnel have been imparted mandatory HSE trainings before being deployed for the job at site, and that they use PPE while on the job. Master of the vessel Responsible for following the marine procedures / guidelines for vessel s operations. Liaises with the concerned process platform personnel, OIM and process manager / logistics manager during SIMOPS involving marine operations.

16 Basic procedures to be followed during SIMOPS: (a) SIMOPS Programme Prior to undertaking SIMOPS, job safety analysis should be carried out by process manager / logistics manager / maintenance manager, as the case may be, with all agencies associated with SIMOPS, to ensure that all the hazards related to the proposed operations are identified, assessed and determined to have the risk as low as reasonable practicable. Job safety analysis report should be approved by OIM. (b) Hazardous Areas Hazardous area drawings for process platform should be made available to the engineering and construction representative before carrying out revamping / construction activities. The work permit should be issued accordingly prior to commencement of activities and regularly monitored during permit duration. (c) Fire water System Availability of fire water system should be ensured during SIMOPS. In the event of its non availability, some of the SIMOPS, as described elsewhere, should not be undertaken. (d) Communication and Coordination Appropriate interfacing and good communication between the key process platform personnel and engineering & construction representative, during SIMOPS related to revamping / construction activities, is to be maintained. Regular meetings, as per written down schedule should be conducted by OIM with the concerned personnel to monitor SIMOPS activities. (e) Station Bill & Mustering If the station bill / mustering points need to be shifted due to revamping / construction activities, prior to shifting, risk analysis should be carried out to identify additional risk, if any, due to the shift, and control measures required. The additional control measures, as required, should be taken before shifting station bill and mustering points. The shifting of station bill / mustering points should be known to all the personnel on board. The shifted points should be properly marked. (f) Emergency response and Disaster Management Plan Offshore installation manager (OIM) is to initiate, intimate and co-ordinate all emergency response actions from the field as per laid down policy of the company Various scenarios under SIMOPS on a process platform related to production activities, revamping / construction activities and marine operations I. Simultaneous activities on a process platform related to production activities: There are many routine operations viz: well intervention (on well platform, bridge connected to process platform), opening of hydrocarbon line, instrumentation calibration, testing of PSVs, helicopter operations, crane operations, supply vessel

17 12 approach, maintenance of gas and fire detectors and fire suppression system, maintenance of life saving appliances, etc carried out on process platform. (i) (ii) (iii) During helicopter operations, crane operations are to be suspended. Maintenance of life boats should not be carried out during well intervention operations, helicopter operations and crane operation involving heavy lifts unless there is stand by capacity available to cater to emergency evacuation of platform personnel. When any of these systems namely fire suppression system, gas and fire detectors is under maintenance, operations like well intervention, opening of hydrocarbon line, instrumentation calibration, testing of PSVs, helicopter operations, crane operations involving heavy lifts, maintenance of life saving appliances are to be performed in a restricted manner with approval of OIM. During diving operations, the routine operations can be carried out on process platform. However, during diving operations, supply vessel approach is not to be permitted, helicopter operation and crane operations with small lifts can be performed with prior approval from OIM, on case- to- case basis. II. Simultaneous activities on a process platform related to revamping / construction activities There are number of activities like painting, hydro-testing, scaffolding erection, working at height, Ultrasonic NDT, radiography, hot work, confined space entry etc related to revamping / construction activities carried out on process platforms. (i) (ii) (iii) (iv) (v) Hydro-testing of equipment is not to be permitted when the fire suppression system, detection (gas & fire) system are not available; other routine activities can be performed only after taking advance approval from offshore installation manager (OIM). During radiography, activities like crane operations and approach of supply vessel can be permitted in a restricted manner with clearance from OIM depending upon radiation level in that particular area. However, other operations can be carried out with approval of offshore installation manager (OIM). During the hot job in the hazardous area on process platform, operations like opening of hydrocarbon line, testing of PSVs, crane operations, maintenance of fire suppression system, gas and fire detectors, life saving appliances and sampling / leak test / venting are not permitted to be performed on platform. However, other operations can be carried out after taking permission from the offshore installation manager (OIM). Confined space (vessel) entry is to be permitted only after obtaining work permit and ensuring vessel is free of hydrocarbon environment with proper ventilation and supervision. Also, before entering, it is to be ensured that oxygen level is in the acceptable range. For further requirements, refer OISD- STD-105 on work permit. When the load is transferred above / near process facility by barge, on process platform, activities namely well intervention, crane operations, maintenance of life saving appliances, fire suppression system, gas and fire detectors, sampling / leak test / venting, radiography, hot work in the process area are not to be carried out.

18 13 (vi) During night time, well intervention operations, maintenance of life saving appliances, fire suppression system, gas and fire detectors and confined space entry are not to be carried out. Helicopter operations, crane operations involving heavy lifts and hydro-testing, should be allowed only after approval from OIM. (vii) When testing ESD / F&G interlocks, operations viz. well intervention, opening of hydrocarbon line, helicopter operations, crane operations, maintenance of gas and fire detectors, sampling / leak test / venting, load transfer above / near the process facility and night operations are not to be carried out. III. Simultaneous activities on a process platform related to marine operations Marine activities include running anchors, hot work onboard vessel / barge, crane operations for load transfers, personnel transfer by crew boat, radiography onboard vessel / barge, diving from vessel / barge, inspection, maintenance & repair activities related to platform, riser installation, in field line pipe installation in the vicinity of process platform etc. (i) (ii) (iii) (iv) Diving is not to be allowed during running of anchors, personnel transfer by crew boat and load transfer between platform and vessel / barge. Supply vessel approach on the same side is not to be allowed during diving from vessel / barge. During load transfer, no operations in the vicinity are to be permitted. During riser installation and infield line pipe installation in the vicinity of platform, the following operations should have prior approval of OIM- supply vessel approach, diving from platform, radiography, running of anchors, diving from vessel / barge and load transfer between platform and vessel / barge. The above scenarios are typical cases. It is recommended that organisation should develop their own SIMOPS matrix, covering all the envisaged activities related to process platform indicating activities which are permitted, which are not permitted and which require prior approval. 4.3 Non-rig related simultaneous activities on a well platform For any non rig related job on an unmanned well platform like wireline, cased hole logging, coiled tubing unit assisted well intervention, revamping / construction etc, OIM shall have the overall responsibility of SIMOPS. Production representative (Wellhead manager) shall oversee SIMOPS on the well platform and shall closely liaise with the designated representative of the service provider. The SIMOPS related requirements as mentioned under SIMOPS on a process platform should be followed, as applicable. 5.0 ONSHORE SIMULTANEOUS OPERATIONS Typical scenarios covered under onshore are: Simultaneous operations involving drilling rig / workover rig, Simultaneous operations inside production installation. The above scenarios are indicative only. The companies should develop their own scenarios based on the risk assessment of various SIMOPS activities.

19 Simultaneous operations involving drilling rig / workover rig : SIMOPS Organisation and management: When the drilling rig / workover rig is operating inside an installation (i.e. a location where oil / gas processing and transportation is being carried out in the vicinity of the well under drilling / workover) or at a cluster location, both the facilities should be defined and considered as a single combined installation. For various SIMOPS, document should be prepared by the company outlining all the dos and don t s, special safety precautions to be taken, roles and responsibilities of key personnel, operations which have to be stopped / can be continued / can be continued with prior approval (at appropriate level), emergency response plan, etc. The person responsible for SIMOPS should be the custodian of SIMOPS document and it is the responsibility of the custodian to seek agreement or approval from appropriate authority for any amendment Responsibilities In case of hired drilling rig / workover rig The responsibilities as enumerated below are also applicable to company owned rigs operating under operation and maintenance / man management contract. Company man The Company representative at the rig, has the overall responsibility for SIMOPS. Controls and regulates the work of the drilling / well intervention programmes on the combined installation. Is authorised, as per Annexure-A, by the company as overall responsible for SIMOPS on the combined installation. Rig Manager Is responsible for the safety of personnel and equipment of the rig and performs work programme approved by the company management. Installation Manager (IM) Any operation in the operating field should be with the knowledge of the installation manager (IM) of the installation to which the well is connected. Liaises with the company man for all operational matters related to SIMOPS and also co-ordinates the shut down requirements of the wells. In case of drilling rig / workover rig inside an installation, though the primary responsibility for SIMOPS is of company man, installation manager (IM) ensures close liaison with the company man, related to SIMOPS In case of company owned drilling rig / workover rig Rig Manager Has the overall responsibility for SIMOPS. Is responsible for the safety of personnel and equipment of the rig and performs work programme approved by the company management.

20 15 Installation Manager (IM) Any operation in the operating field should be with the knowledge of the installation manager (IM) of the installation to which the well is connected. Liaises with the rig manager for all operational matters related to SIMOPS and also coordinates the shut down requirements of the wells. In case of drilling rig / workover rig inside an installation, though the primary responsibility for SIMOPS is of rig manager, installation manager (IM) ensures close liaison with the rig manager related to SIMOPS Basic procedures to be followed during SIMOPS: (a) SIMOPS Programme Prior to undertaking SIMOPS, job safety analysis should be carried out by the person responsible for SIMOPS (company man / rig manager, as the case may be) with all agencies associated with SIMOPS, to ensure that all the hazards related to the proposed operations are identified, assessed and determined to have the risk as low as reasonably practicable. Job analysis report should be approved by installation manager (IM). (b) Well Closure In case of drilling / workover activity inside an installation / at cluster location, prior to movement of the rig, detailed risk analysis should be carried out to determine the additional risks imposed due to drilling rig / workover rig related activities inside the installation / at cluster well location and additional controls required to handle these risks under the following scenarios : - production activities can continue during all phases of drilling rig / workover rig activities with / without some restriction. - production activities are to be suspended only till rig building stage and thereafter during rig dismantling and its transportation stage. - production activities should remain suspended during period drilling rig / workover rig is inside the installation / at cluster locations. Only after the additional control measures are in place, corresponding to one of the above scenarios, drilling rig / workover rig related activities should be undertaken under that scenario. (c) Hazardous Areas If rig is to be inside the installation, hazardous area classification drawing of the installation and rig s hazardous area classification drawing should be combined to establish a composite hazardous area classification drawing. (d) Fire water System The rig should have independent fire suppression system which can handle fire on the rig and the cluster well. Fire fighting hoses and fire nozzles should be strategically positioned, and regularly tested. (e) Communication and Coordination

21 16 Appropriate interfacing and good communication between the installation and drilling rig / workover rig throughout the simultaneous activities is to be maintained. Company man / rig manager, as the case may be, should hold regular meetings, as per written down schedule, with all the concerned personnel to review SIMOPS. (f) Drilling Station Bill & Mustering The drilling rig / workover rig should initiate a SIMOPS Induction for all personnel when they arrive on the rig. The personnel should be aware about the mustering points which should be used in case of emergency. (g) Emergency response In the event of any emergency on the rig involving a cluster well or installation having rig inside, it is the responsibility of the company man / rig manager, as the case may be, to initiate and co-ordinate all emergency response actions as per approved SIMOPS documents, in close liaison with IM Simultaneous operations involving drilling rig / workover rig, at cluster locations include I. Movement of drilling rig / workover rig around the producing oil / gas wells, II. Skidding of drilling rig and shifting of drilling rig / workover rig in cluster location, III. Drilling / workover on one well and activation of / wireline job on another well in the cluster, IV. Drilling / workover on one well and CTU / Stimulation job on another well in the cluster, V. Drilling rig / workover rig inside the installation. At a cluster location, more than one well is drilled from the same plinth. These may involve simultaneous operations like well drilling / workover operations / production related activities, at the same location. The SIMOPS may take place under various scenarios like: (a) (b) (c) One well is under production and the rig building is in progress for drilling second well. One or more wells are on production and the drilling / workover operation is in progress on another well. One well is under drilling, another well is under workover operations and other wells are under production. This scenario should be avoided. The cluster wells are generally adequately spaced for carrying out drilling / workover operations in each well without creating any hindrance during transportation, rig building and rig dismantling. The routine operations involved in a producing well include: (a) (b) (c) Mechanical scraping, Bottom Hole Studies Artificial lift monitoring / servicing / optimization, etc

22 17 (i) (ii) (iii) (iv) (v) (vi) (vii) (viii) (ix) (x) In cluster drilling, a concern is below surface collision of the well with the neighbouring well. The higher risk is in the upper part where all the wells are close to each other, but risk at depth still exists. Precautions should be taken while preparing well programme (well profile) to avoid this kind of situation otherwise consequences can be serious when the producing well is hit. The SIMOPS checklist is to be filled up by company man / rig manager and installation manager as shown as Annexure G, to ensure that all preparatory works have been completed prior to rig movement. The cluster wells normally should not be permitted to flow during transportation, rig building, rig dismantling (refer (b)). The cluster wells should be permitted to be flown only after taking approval from SIMOPS incharge. The escape routes of drilling rig / workover rig should be free from any obstruction. Hazardous zone classification around cluster wells should be done as per latest guidelines of DGMS and hazardous zones should be free from any spark from engine exhaust / electric motor. The electrical equipment should be suitable for the hazardous area. The Xmas tree of cluster wells and flow lines / injection lines should be protected by means of temporary physical barrier above and around it, so that the same may not be damaged by falling objects and inadvertent hitting by rig equipment. The cluster wells should be taken up for temporary protection before the drilling rig / workover rig moves in. Around the producing wells in the cluster, presence of gas to be monitored at pre-defined intervals and records maintained. Possibility of installation of continuous gas monitoring system with a panel at driller's console connected to gas detecting probes placed at specific locations at the producing well / stand alone portable gas detectors covering large area, may be looked into. Besides monitoring of gas around the producing wells, continuous monitoring for the presence of gas be undertaken, at cellar pit of drilling well, and at mud channel at shale shaker end and corrective actions be taken as necessary and records maintained. In case of major leakage of oil / gas at the plinth, the company man / rig manager, as the case may be, should stop drilling operation till the leakage is rectified and the well has been brought to the safe condition. There should be a written down procedure to tackle the presence of gas, around the producing wells and at the rig. Minimum three 20 Kg DCP trolley mounted fire extinguishers should be placed in a cluster area. Flow line and gas injection line from / to the producing wells should be laid at an adequate distance from substructure of rig and buried as far as possible or re- routed, if required to avoid damage during drilling / workover, rig building / dismantling, transportation etc. Caution notice board mentioning "DANGER - High pressure gas line / oil flow line" should be displayed at appropriate places. Caution board mentioning "DANGER - Well on production" should be displayed at the producing well(s).