1 SCOPE

This document provides the minimum requirements to carry out simultaneous operations.

2 REFERENCES

not applicable

3 OPERATING PHILOSOPHY

3.1 COMBINED INSTALLATION

Installations, comprising a rig, platform and/or production facility, become combined when they have or will have an interface, e.g. emergency shut-down, deluge system, PA system, etc.

3.2 SIMULTANEOUS OPERATIONS

1. Simultaneous Operations (SIMOPS) occur when any kind of activities are taking place concurrently in Combined Installations.

2. Activities include (but are not limited to) production, construction, maintenance, well operations, workover, well testing, well servicing, rig moves, diving, heavy lifts and transport operations.

3.3 COMBINED INSTALLATION SAFETY PLAN

1. A Combined Installation Safety Plan shall be prepared for each location where installations are going to be combined.

3.4 SIMULTANEOUS OPERATIONS SAFETY PLAN

1. A Simultaneous Operations Safety Plan shall be prepared for each location where simultaneous operations are going to take place utilising a competent survey.

2. Such a survey should include, but not be limited to:

  • Electrical requirements of both Rig and Platform or Production Facility,
  • access (stairs or bridge), o alarm systems interface,
  • Emergency Shut Down (ESD) control,
  • Communications between installations.

3. The SIMOPS document shall include all subjects required of the survey together with specifics regarding dual lift, roles and responsibilities, reporting lines, Safety Meetings, risk assessment documents, personnel movement control (T-card System) and a SIMOPS matrix tabulating events and actions. The Plan shall include well hand-over Forms which will be kept on file.

4. The SIMOPS Plan shall be approved by both Well Operations and Production Operations Management, or in other cases both Management Teams.

3.5 PERSON IN CHARGE

1. A Person In Charge (PIC) shall be nominated for managing the Combined Installations where simultaneous operations are carried out

2. The person in charge (PIC) shall be competent to co-ordinate all operations taking place in a Combined Installation.

3.6 QUALIFIED PERSON

1. A Qualified Person (QP) shall supervise Simultaneous Operations.

2. Supervisors (QP) have the responsibility for reporting status, and change of status, to the Person In Charge (PIC). Site audits should be carried out jointly by QP and PIC.

3.7 WHEN INSTALLATIONS BECOME COMBINED OR CEASED TO BE COMBINED

1. It shall be a formal hand-over agreement that shall be signed by the different parties to acknowledge the change of responsibilities.

3.8 SIMOPS CO-ORDINATION MEETING

1. A SIMOPS co-ordination meeting shall be held on a daily basis. All on-site supervisors (QP) and others personnel requested for the effective conduct of the meeting shall attend.

2. The meeting should address the planned operations for the day and identify any hazard that may arise from the SIMOPS.

3.9 GENERAL RULES

1. Only one live well activity can be carried out at a time.

2. Any event jeopardising well control (e.g. kick, losses) shall require an immediate suspension of SIMOPS activities.

3. When drilling from a cluster, in case the ellipse of uncertainty of the well being drilled intersect the ellipse of uncertainty of the producer or injector well, the producer or injector well shall be isolated with a tested barrier at a depth located below a potential point of intersection and its annulus bleed off to zero.

4. Production operations shall be partially of totally shut down when carrying out certain well operations such as heavy weigth handling close to production Xtrees

5. An Operations Decision Matrix shall be prepared for each installation. The PIC shall ensure that this Matrix is posted on the installation.

6. Hot Work is prohibited in the operation and production areas when conducting SIMOPS involving live wells.

4 APPOINTMENTS AND RESPONSIBILITIES

4.1 PERSON IN CHARGE APPOINTMENT

1. For each installation where Combined Operations will be carried out, a single person who shall have overall authority and responsibility for all operations shall be appointed as Person In Charge (PIC).

2. In the case of a Production Facility the dedicated Installation Manager or for a Platform or large Offshore Complex the dedicated Offshore Installation Manager (OIM) or Field Manager can be appointed PIC.

3. In the case of well operations activities on non manned installations (Jackets, isolated clusters or production facilities) the Well Operations Supervisor can be appointed PIC.

4.2 QUALIFIED PERSON APPOINTMENT

1. In a Combined Installation, Qualified Persons (QP) shall be appointed to supervise each zone of activity.

2. The two main activity zones are the well operation or intervention area and the Production facilities.

3. The well operation or intervention area also includes the associated equipment to the unit (rig, snubbing unit, workover rig, etc) and the well in which the operation is taking place.

4.3 OPERATIONS MANAGER RESPONSIBILITIES

1. Operations Manager responsibilities include:

a. Approval of the Combined Installation Safety case
b. Approval of the SIMOPS safety case
c. Appointing a specific PIC for the installation and define the reporting relationship
d. Defining the boundaries of the PIC responsibilities and authority.

2. Operations cannot commence if the Combine Installation Safety case and the SIMOPS safety case have not been approved by the Operations Manager.

3. Once the Combine Installation Safety case and the SIMOPS safety case have been approved, the Operation Manager can then authorise the rig move.

4.4 PERSON IN CHARGE RESPONSIBILITIES

1. The PIC shall have overall responsibility for all activities on the Combined Installation within the boundaries defined by the Operations Manager

2. A PIC should permanently be on the site.

3. The PIC shall approve all work permits.

4. Ensure compliance with rules, regulations, risk control policies and procedures.

5. Define priorities for SIMOPS in cooperation with the QP.

6. Ensure proper co-ordination and management of SIMOPS activities.

7. Initiate further risk assessments and associated mitigating measures as required.

8. The PIC shall organise contractor’s pre-job safety meetings prior to start live well activities. All concerned personnel including the QP shall attend these meetings.

9. A daily meeting shall be held by the PIC between the principal parties (OIM, QP, Safety etc) to facilitate planning and safety of SIMOPS. At this meeting the safety, status and production parameters of all production and injection wells shall be reviewed.

4.5 QUALIFIED PERSON RESPONSIBILITIES

1. Carry out operations in compliance with GDF SUEZ EPI Policies, Procedures and Rules.

2. Immediately inform the PIC of any significant change to the work programme or abnormal situation and generate a Mangement of Change procedure.

3. Shall liaise with other QP and supervisor working on the same Combined Operations.

4. Ensure that a proper hand over is performed at the end of each shift.

4.6 CONTRACTORS INSTALLATION MANAGER OR OIM

1. The Contractors Well Site Manger or OIM shall:

a. Have full responsibility over the rig, rig equipment, and all personnel associated with or onboard the rig.

b. In emergency situations shall have full responsibility for the final decision for the safety of the rig and all personnel onboard.

2. The Installation Manager or OIM can be appointed PIC.

5 OPERATIONS MANAGEMENT

5.1 PRIOR TO RIG MOVE

1. As part of the Combined Installation Safety Case, prior to moving a rig onto location, all measures to be taken for the safe conduct of all activities must be clearly identified.

2. Requirements for shutting in sensitive areas of the platform or production facility will be assessed. These risk assessments will involve all respective department (production, well operations, construction, marine, etc.).

3. Well status shall be assess, like presence of pressure in the different annulus and associated riks; necessity to bleeding off has also to be assessed.

5.2 PRIOR TO COMMENCEMENT OF SIMOPS

1. A kick off meeting shall be held prior to commencement of SIMOPS to highlight potential risks and their associated mitigating measures.

2. The Operations Manager, PIC, QP, Contractor supervisory personnel and onshore/offshore safety and operations management personnel shall attend this meeting. At this meeting personnel will be provided with Well Operations Policies for SIMOPS.

3. The meeting shall also address:


a. Status of all facilities (including wells)
b. The Operations Programme outlines.
c. Responsibilities and the role of all supervisors involved in Simultaneous Operations.
d. Main Operations procedures taking into consideration the SIMOPS matrix.
e. The Work Permit procedure that will be used in the Combined Installation.

6 COMBINED INSTALLATION SAFETY CASE

6.1 DESCRIPTION OF THE COMBINED INSTALLATION

6.1.1 DESCRIPTION OF THE INSTALLATION

1. The Combined Installation Safety Case (CISC) shall provide a brief description of the installations and of the interface that have been put in place to allow operations to be carried out simultaneously such as:

a. Emergency shutdown (ESD) with different levels of action
b. Deluge systems
c. Fire and gas detection
d. Additional equipment installed (e.g. lighting, high pressure pumping lines…etc.)
e. Communication system: PA system, Walky-talky radio frequencies…
f. Alarm system in place (e.g. if alarm signal different on the platform or production facility and on the rig)
g. Venting of the platform or production facility in case of hydrocarbons release
h. Helidecks: which one will be used for normal personnel shuttle or emergency evacuation
i. Cranes from both platform or production facility and rig
j. Earthing
k. Muster point
l. Escape evacuation access and route
m. Personnel tracking.

6.1.2 ENVIRONMENTAL POLICY

1. This section shall describe the Spill contingency plan that has been developed for these particular operations. Note that a plan should already exist if the SIMOPS are conducted from a platform or production facility.

2. This section shall also explain the waste management plan for all industrial wastes generated on the combined installation (when applicable).

6.1.3 SETTING AND MEASURING PERFORMANCES

1. Here shall be described the targets set for involved parties, including GDF SUEZ, and their follow up.

2. As matter of example:

a. Compliance with standards
b. Environment
c. Reporting system
d. Improvement exercises like safety drills
e. Safety job assessment
f. Safety cards

6.1.4 ROLES AND RESPONSIBILITIES

1. Determine who is going to be the ultimate site representative responsible for the duration of the combined operations, e.g. PIC or Offshore Installation Manager of the rig or of the platform/production facility or Operation Supervisor in case of isolated land operations or non-manned platforms or production facilities.

2. Organization of each party involved in these Combined Operations must be shown, e.g. GDF SUEZ EPI will appoint dedicated PIC, QP, Well Operations Engineers, Well Operations Superintendent, and Well Operations Supervisor for this particular operation and the relation they will have with the personnel of the other companies:

a. Working schedule of the contractors.
b. Responsible person for the contractors (foreman).

6.1.5 COMMUNICATION BETWEEN THE PARTIES

1. Description of the different meetings to be held onshore and offshore and the different subjects they cover should be noted. Note that some of these meetings are already covered in this section 6.

2. Regular reviews of the standard of Hand-overs between key personnel should be undertaken. Key personnel e.g. QP and Operation Supervisor should not have the same rotation schedule.

3. Frequency of reporting: e.g. the Well Operations Supervisor will report, as required, on a daily basis to the Well Operations Superintendent, the QP will report as required to the PIC.

4. Communication of any change of programme within the Combined Installation: should be intimated during either a meeting or over the PA system. This is the responsibility of the QP to inform the PIC of any change of work scope.

6.1.6 PERSONNEL

1. This section defines Personnel related matters:

a. Manning level: maximum number of persons on board the Combined Installation – should be detailed both on the rig and on the platform or production facility.
b. Movement of personnel within the installation and the tracking of personnel within the boundary of the different activities areas of the Combined Installation should be kept.
c. Different crew rotation system and working schedule should be noted.
d. Crew competency should be recorded.
e. Crews training and co-ordination of simultaneous operations, responses to alarms should be recorded.
f. Offshore orientation and safety briefing for personnel arriving on board the Combined Installation should be in place.

6.1.7 ONSHORE EMERGENCY RESPONSE

1. Details of personnel and the organization involved in Emergency response onshore, and the location of the emergency room (either at Company offices or at Contractor facilities) should be available.

2. Personnel’s relative interface will be coordinated by GDF SUEZ EPI.

3. Media communication will be coordinated by GDF SUEZ EPI.

6.1.8 OFFSHORE EMERGENCY RESPONSE

1. In this section will be detailed the roles and responsibilities of the key offshore personnel and the non key personnel.

2. The emergency procedure will also be detailed including driller’s response to alarms e.g.
securing the well and procedures.

6.1.9 OIL SPILL RESPONSE

1. GDF SUEZ EPI will organize the oil spill response in accordance with the existing platform or production facility Oil Spill Emergency Plan and mobilize equipment and personnel.

6.1.10 ACCIDENT/INCIDENT REPORTING AND INVESTIGATION

1. This section describes how incident reporting is managed by both the Company and the Contractors.

2. For GDF SUEZ EPI Incident reporting standard, refer to WOR 7 - Incident Reporting.

3. Even minor incidents or accidents will be reported and noted in the daily report. In some instances an investigation team may be sent to thoroughly examine the incident.

6.1.11 OPERATION PROCEDURES

1. A detailed Daily/Operational plan will be prepared by the Well Operations Supervisor based on the Well Programme and ongoing operations at the time, this should be reviewed by the Well Operations Superintendent and Well Operations Engineer and after approval it should be made available to all the relevant personnel.

6.1.12 WELL CONTROL

1. A description of the well control procedures which are to be used during the Well Operation should be agreed and made available to all necessary personnel. The Drilling Contractor’s procedures usually take precedence.

2. If necessary a ‘joint well control manual’ and/or ‘joint drilling manual’ will be prepared between the Company and the Contractor.

6.2 SIMOPS SAFETY DOCUMENTATION

1. Prior to moving the rig onto the site the SIMOPS Safety Documentation shall be gathered and include all relevant information such as:

a. Operating manual or equivalent
b. General Safety and Environment Well Operations Policies.
c. Contingency Plans
d. Work Permit procedures.
e. WOR related to SIMOPS
f. Combine Installation safety case
g. The Risk assessments
h. The acceptance reports on works to be completed prior to rig installation (arising from the installation survey) (covered in the Combine Installation safety case).
i. Procedures for the testing of platform or production facility safety equipment and system inhibition when the Combined Installation is operational.

2. A File shall be maintained by the PIC that:

a. Records equipment inspection for both platform or production facility and rig.
b. Records all other required inspections.
c. Records the testing of safety equipment and systems and any follow-up (safety equipment on both Rig and platform or production facility)
d. Includes closed out work permits and isolation certificates.
e. Includes the facilities hand over file.
f. Includes the minutes of the daily meetings.

6.3 SAFETY

1. The following safety measures shall be carried out:

a. Incident reporting including near misses.
b. Follow up of all anomalies and failures.
c. Tracking and recording of personnel on the installation and the restrictions on the number of allowable personnel.
d. Regular emergency drills including those related to live well activities.
e. Monitoring of all pre-job safety meetings.

6.3.1 WORK PERMIT

1. The activities subject to a Work Permit shall be defined in the Simultaneous Operations safety case.

2. A joint approval (platform/production facility/rig) procedure for PTW (Permit to Work) shall be defined.

3. Third parties PTW would have to be submitted either in the platform/production facility or on the rig depending where they take place.

6.3.2 CRANE OPERATIONS

1. Operations involving cranes from both the Drilling Unit and the platform or production facility should be reviewed especially during SIMOPS and an operational procedure shall be in place to avoid conflicts.

2. Communication between cranes must also be detailed.

3. Particular attention must be given to over the side crane operations that could take place over a production pipe line.

6.4 PIC HANDOVER

1. The PIC shall maintain a logbook and record as a minimum:

a. Minutes of safety pre-job meetings.
b. Any incidents, failures and relevant conclusions/solutions.
c. Suggestions for improvements.

2. At the time of shift changes, the new PIC shall certify in the logbook that he is fully aware of all operational and safety matters that have taken place in the previous period of time.

6.5 SUPERVISION

1. Twenty-four hour per day supervision is required of the following operations during SIMOPS:

a. Well servicing or well testing operations, even in the case of non eruptive wells.
b. Any hot work permit activities.
c. Rig moves close to production facilities or heavy vessel movements in restricted access areas.
d. Heavy lifts above or close to production facilities.