SAFETY, ENVIRONMENTAL MANAGEMENT Safety procedures plan provides platform-to-platform uniformity

Program enhances confidence for new and contract
operations, maintenance

Wanda June Parker
Oryx Energy
Steve Hanus
Mustang Engineering

The density of equipment aboard offshore production platforms makes uniform procedures for operations and control necessary for safe intervention. Oryx used a new uniform management practice on the High Island A-379-B platform deck being installed near the Flower Gardens reef sanctuary in the US Gulf of Mexico.

A safety and environmental management program (SEMP) has been recommended by the American Petroleum Institute since 1993 as its recommended practice (API RP75). The program is endorsed by the US Mineral Management Service (MMS) in order to promote the safety and environmental protection of offshore operations on the US outer continental shelf.

The plan addresses the management of hazards associated with facilities design, construction, startup, operation, inspection and maintenance. Additionally, SEMP provides a means for ensuring that the program elements are properly utilized, documented, and available on location or at the operations office.

Although SEMP is a newly recommended program, its principles and concepts have been applied by many OCS operators for years. Many day-to-day operating procedures offshore follow guidelines incorporated into SEMP documents. SEMP's value, though, is to integrate available information and to provide a suitable framework for documentation and implementation of safety and environmental procedures tailored specifically to an operator's needs.

Oryx Energy and Mustang Engineering collaborated on such a program for Oryx, incorporating site-specific details for the company's High Island A-379-B production facilities off Texas. This particular platform was a new installation located within the four mile zone of the environmentally sensitive Flower Garden Banks National Marine Sanctuary.

Program

The complete SEMP program is segmented into 12 parts. With knowledge of the SEMP requirements, certain existing company operating procedures can be re-formatted and inserted into the appropriate section of the plan. Information not currently available can be modified from other programs, and when available, placed in the plan document as well. A brief synopsis of the program segments follows:

Purpose and objective: The initial segment of the plan defines the contents, provides definitions, and identifies the intended applications.

Safety, environmental information: This section addresses both the process and mechanical/facilities designs. The process design information includes simplified process flow diagrams and acceptable upper and lower process limits for such variables as temperature, pressure, flow and composition. In the mechanical/facilities portion, diagrams of piping, instruments, and equipment arrangement are included. Alarms, shutdowns, interlock systems and well control system descriptions are also contained in this section. This portion of SEMP includes the design basis for fire protection and relief systems, as well as emergency evacuation procedures. Guidance for construction of the mechanical portion of this section can be found in API RP14J and API RP75.

Hazards analysis: The analysis contained in this section corresponds to API RP 14J, seeking to identify, evaluate, and provide tools for reducing the likelihood, and minimizing the consequences of safety or environmental incidents. The section lends itself to several approaches - a checklist, what-if evaluation, or a Hazop analysis. Priorities need to be established on both new and existing facilities, according to the severity of the operating conditions.

Management of change: This section relates to the procedures necessary to identify and control changes in equipment, process conditions, or personnel. It provides communications tools to allow affected personnel to be immediately cognizant of any change that occurs at the site.

Operating procedures: This segment of SEMP includes detailed operating procedures designed to enhance efficient and safe operations. It denotes facilities operating parameters, relates MMS lease stipulations, details procedures, identifies appropriate supervisory personnel responsible for implementation, and provides precautionary and control measures for environmental safeguarding.

Safe work practices: This portion deals with the establishment and implementation of safe work procedures to minimize operating risks. The section can include safety manuals, work rules and, where necessary, site specific regulations.

Training: The training section, as expected, establishes appropriate programs so that all personnel are trained to work safely and can be aware of environmental considerations in the offshore workplace.

Quality assurance, mechanical integrity of critical equipment: The operation's critical equipment is identified in this section of the plan. Procedures are delineated for the inspection, monitoring, and maintenance of the equipment consistent with the service requirements, industry standards, or the manufacturer's recommendations. The equipment in this section would include piping, wellhead valving, blowout preventers, flares and fire protection equipment, to name just a few, and when it is pertinent, site specific equipment such as helidecks, escape capsules, and storage facilities can also be addressed.

Pre-startup review: If the SEMP program is being implemented at initial start-up or after a major revamp, procedures need to be put into place to assure safe operation to personnel and the environment. Verification of construction safety procedures and hazardous analysis can be accomplished here.

Emergency response, control: Emergency response and control plans are noted here to assure that they are in place and ready for implementation as needed.

Investigation of incidents: This segment of the plan establishes procedures for incident investigation regardless of their magnitude or impact on safety or the environment.

Audit of safety and environmental management program elements: This final section sets up an audit procedure to assure that the SEMP plan is maintained. The plan calls for an initial audit within two years of implementation and periodic audits within four year intervals. The results of audits at a minimum of 15% of the field locations will indicate whether further investigations or changes to SEMP plan segments 2-10 need to be made,

Benefits

As with most other offshore operators, Oryx Energy has had written operations, safety, environmental and maintenance procedures in place for some time and available at each of its offshore facilities. Additionally, the company has employed managers specifically to oversee these procedures. How then, did the SEMP implementation benefit Oryx, and how will it similarly benefit other operators?

The SEMP program provides an operator with a standard set of comprehensive guidelines for operating and controlling each of its offshore facilities. Since it is site specific, it further identifies those concerns particular to that facility. When used on Oryx platforms, it helped provide a uniformity of procedures that allowed company personnel to come on Oryx facilities and work with confidence.

Since many operators rely on contract personnel for certain maintenance and operations, SEMP provides a standard for their performing duties safely and without confusion. Once contractor personnel have been instructed on company SEMP particulars and know the whereabouts of the manuals on site, the workers can move among company platforms with an understanding of required procedures and potential hazards. This immediate knowledge saves both time and money, since extensive orientations at each location are not necessary before work commences.

For platform HI A-379-B, since it was a startup situation, the SEMP program was instituted during the platform's design phase. This enabled Oryx to enact minor design changes prior to installation, ultimately saving time and reducing startup costs.

In constructing its hazards analysis, Oryx followed a Mustang Engineering-prepared checklist developed for global use on all of the company's platforms and then applied to HI A-379-B simply by eliminating those elements non-applicable to that installation. This approach enabled Oryx to have an existing program for all future installations.

To verify the effectiveness of this SEMP segment, Oryx evaluated representative pieces of equipment on the platform and then employed an independent engineer to conduct an unbiased hazards analysis. This method of verification enabled Oryx to identify and correct minor issues that warranted modifications in procedure.

The management of change procedure provided Oryx with a clear mechanism for internal communication and offered a means of keeping any changes well documented. Since the field superintendents are responsible for approving changes, this segment of SEMP designated singular responsibility and placed accountability for document updates at the field level.

Oryx organized its formal startup review into two approaches. It provided a checklist for field personnel, enabling them to readily pre-condition and commission equipment at startup. Additionally, it assigned a company inspection team - including safety and environment specialists and mechanical, facilities and operations engineers - to conduct a platform walk-through prior to startup, promoting a quicker and safer startup.

To adhere to SEMP's segment concerning emergency response and control, the company annually conducts a minimum of two drills for its offshore operations. These real-time exercises cover all aspects of the plan. The scenario varies for each drill and involves a broad spectrum of company employees, including administrative personnel, management, field personnel, and the public relations crisis response team. Specific parts of SEMP implemented initially at the HI A-379-B platform included such details as the names and phone numbers of individuals to be contacted in any form of emergency.

A recent survey conducted by API assessing the implementation status of RP75 indicated that almost 95% of US Gulf of Mexico operators are already in the process of implementing the plan to varying degrees. SEMP has not yet become a mandatory requirement for offshore operators. If it parallels the OSHA CFR 1910.119 for onshore facilities, however, it could ultimately become a requirement. In the meantime, it can be a very useful tool for providing cost savings while increasing personnel safety.

Whether it becomes mandatory or not, to be most effective and beneficial, all aspects of the plan need to be thoroughly reviewed, involving management and staff participation. The implemented program needs to include enough detail to be useful to field personnel, but also be flexible enough to include information that is pertinent to daily operation. The involvement of a specialist in SEMP and manuals preparation should be considered in order to prepare the most appropriate document.

AUTHORS:

Wanda June Parker, P.E., is manager of offshore environmental and regulatory affairs for Oryx Energy. She is a graduate of Texas A&M and a registered engineer in Texas. She has eight years experience in the environmental and regulatory segment of the industry with Oryx, much of it devoted to offshore.

Steve Hanus is a consulting engineer for Mustang Engineering in Houston. He has more than 25 years experience in the oil and gas, petrochemical, chemical, and other process industries. He has significant experience in developing compliance manuals for OSHA CER 29 Part 1910, SEMP, and facilities operating manuals.