UPSTREAM SAFETY MANAGEMENT STRIVES TO REDUCE RISK TO PERSONNEL AND ENVIRONMENT

Guntis Moritis
Production Editor

Management of safety in oil and gas production aims at a more proactive approach that combines both health and environment. Safe operations generally result in environmentally prudent practices.

The industry is striving to develop clear corporate policies and objectives that ensure that process standards, guidelines, and procedures are followed. Training of employees is at the core of most safety programs.

Production operation safety is focused toward offshore operations where loss of life and environmental damage can be much more devastating. The Piper Alpha disaster in 1988 is a prime example, claiming 167 lives and total loss of platform.

The Cullen report on Piper Alpha identified the need of industry to focus more on management of safety rather than on just improving technology.¹

API RECOMMENDATIONS

API's RP 75, Recommended Practice for Development of a Safety and Environmental Management Program for Outer Continental Shelf (OCS) Operations and Facilities, first edition, May 15, 1993, provides guidelines for preparing safety and environmental management programs (SEMP). These guidelines cover well drilling and servicing, and production and pipeline facilities and operations.

In 1993, API presented three workshops, in different cities in the U.S., on these practices and now is in the process of surveying the industry to benchmark the progress in implementing the recommendations. According to API, RP 75 attempts to preclude possible future U.S. government regulations by developing voluntary safety and environmental management programs.

In general, RP 75 follows U.S. Occupational Safety and Heath Administration (OSHA) process and safety regulations, although API describes RP 75 as not as complex as OSHA's regulations and written specifically for offshore operations.

RP 75 also provides for a self audit and suggests an implementation schedule on the frequency of the inspections needed per year.

Procedures to evaluate hazardous operations are covered in RP 14J, Design and Hazards Analysis for Offshore Production Facilities, first edition, Sep. 1, 1993. RP 14J discusses several procedures for performing a hazards analysis and presents minimum requirements for process safety information and hazards analysis to satisfy RP 75.

Some of the other API publications that cover safety are as follows:

Spec. 14A, Specification for Subsurface Safety Valve Equipment, ninth Edition, Dec. 1, 1994
RP 14B, Design, installation, repair and operation of subsurface safety valve systems, fourth edition, July, 1, 1994
RP 14C, Analysis, design, installation and testing of basic surface safety systems on offshore production platforms, fifth edition, Mar. 1, 1994
Spec. 14D, Specification for wellhead surface safety valves and underwater safety valves for offshore service, ninth edition, June 1, 1994
RP 14E, Design and installation of offshore production platform piping systems, fifth edition, Oct. 1, 1991
RP 14F, Design and installation of electrical systems for offshore production platforms, third edition, Sept. 1, 1991
RP 14G, Fire prevention and control on open type offshore production of platforms, third edition, Dec. 1, 1993
RP 14H, Installation, maintenance and repair of surface safety valves and underwater safety valves offshore, fourth edition, July 1, 1994
RP 55, Conducting oil and gas producing and gas processing plant operations involving hydrogen sulfide, second edition, Feb. 15, 1995.

OFFSHORE TRAINING

Training is an important part of a safe operation. One facility dedicated to this is Chevron Corp.'s employee resource and training center (ERTC) in Lafayette, La. Although initially setup to train Chevron's offshore and overseas personnel, in 1994 the facility started accepting personnel from other major companies such as Amoco Corp., Conoco Inc., Phillips Petroleum Co., and Unocal Inc.

The center serves about 1,100 workers who need to update safety training to meet 30 CFR 250 Subpart O safety regulations. The main part of the course includes excerpts from 30 CFR 250 Chapter 2, API RP 14C, API RP 14B, API RP 14H, safety analysis function evaluation (SAFE) charts, testing, and record keeping.

The course covers any offshore safety equipment such as level, pressure, and temperature controllers, pressure shut-off valves, flow shut-off valves, flare arrestors, and downhole safety valves.

The safety device symbols used offshore are derived from and loosely conform to Instrument Society of America standards.

Functional devices are identified by three letters as follows:

The first letter is a variable such as P (pressure), T (temperature), L (level), etc.
The second letter is S (safety) for sensing and self-acting devices, or A (alarm) for alarm only devices
The third letter is the direction variable, H (high), L (low) sensor, or type of device Y (valve), and E (element).

Fig. 1 (12095 bytes), Fig. 2 (22135 bytes), and Fig. 3 (24329 bytes) show some of the main types of safety valves and regulators discussed in the course. The course covers operations as wells as disassembling cleaning, reassembling, and testing of the safety equipment.

Other parts of the course cover gas detectors and fire detection systems (ionization, photoelectric, thermal bimetallic, thermal diaphragm, infared, and ultraviolet), as well as reporting, preventing, isolating, and recovering hydrocarbons releases.

One main component is the analysis of the platform schematics through SAFE charts.

Anyone who tests, repairs, or does preventive maintenance on the equipment is required to attend. Mineral Management Service (MMS) of the U.S. Department of Interior audits the course material.

MMS guidelines are slanted toward pneumatic systems. Now with programmable logic controllers (PLCs) and supervisory control and data acquisition (scads) systems, equipment testing frequency requirements may be changed. Some monthly tests may be allowed to be completed quarterly. The course length at Chevron's school is 48 hr and offshore personnel need to attend the basic course every 4 years and complete a 1 day, 8 hr, refresher every 2 years.

WORLDWIDE CONCERN

Concern about safe oil and gas operations is worldwide. The recent Offshore Southeast Asia conference and exhibition, Singapore, Dec. 6-9, 1994, had a number of papers presented on the topic.

In one presentation, K.T. Ming described the enhanced safety management (ESM) that Sarawak Shell Berhad and Sabah Shell Petroleum Co. Ltd. have implemented in East Malaysia since 1985.¹ The program was further expanded to a safety management system (SMS) in 1993 by including quality management techniques whereby safety focus was redirected to include nontechnical causes for accidents.

ISO 9001, "Quality systems-Model for Quality Assurance in Design Development, Production, Installation, and Servicing, 1987," covers international quality standards.

Points included in Shell's ESM are:

Visible management commitment to safety
Sound safety policy
Safety as a line management responsibility
Competent safety advisers
High, well-understood safety standards
Techniques to measure safety performance
Realistic safety targets and objectives
Audits of safety standards and practices
Effective safety training
Thorough accident investigation and follow-up
Effective motivation and communication.

Since being introduced in 1985, according to Ming, lost time incident frequency (LTIF) dropped in 1993 to 0.6 from the 1.6/million man-hours in 1985.

As the basic framework for its initial safety management system (SMS) for the development of the Xiajiang oil field in the Pearl River Mouth basin of South China, Phillips Petroleum International Corp. Asia and its co-ventures, according to Bobin and Rule, used API RP 750, "Management of Process Hazards," and OSHA's regulation 29 CFR 1910.119, "Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents (PSM)," along with the Phillips Petroleum Co. safety policy manual. They said that the SMS was further refined by including the international safety rating system used within Phillips in other operations to write a 15 point core safety policy as follows:

Leadership and administration
Training
Planned inspection, test, and maintenance
Hazard analysis
Accident/incident reporting, investigation, and analysis
Emergency planning and response
Organization rules
Personal protection equipment
Auditing
Management of change
Communications
Contractor safety
Purchase controls
Health control
On-the-job safety.

NORM

As brought out by Briscoe and Wajidi,³ naturally occurring radiation material (NORM) is a potential problem for the industry in Malaysia. Formal guidelines for dealing with NORM were introduced in 1991 and are similar to the guidance document of the U.K. Offshore Operators Association.

In Malaysia, the permissible limits for surface contamination and disposal are 0.04 Bq/sq cm for alpha emitters and 0.4 Bq/sq cm for other radioisotopes. Scale activity has been found to be in excess of 20 Bq/sq cm. There are 37 billion Bq (Becquerels) per Curie of radioactivity. Options to deal with scale include: ³

Offshore decontamination
Onshore decontamination
Disposal such as being crushed to minimal size and dispersed in the ocean, injected into disposal or abandoned wells, or filtered and dried for permanent containerized storage.

For the U.S. industry, API Bulletin E2 , Management of Naturally Occurring Radioactive Materials (NORM) in Oil & Gas Production, first edition, Apr. 1, 1992, provides guidelines for controlling and disposing of NORM contaminated equipment and scales.

HUMAN FACTOR

One safety area receiving more attention is the human factor that determines if jobs are structured to be within human capacities. The challenge according to Brabazan, et al.,4 is to find cost-effect ways to bring human factors into the design considerations. An ergonomic checklist presented by them is as follows:

Equipment controls should be easily identified, reached, and operated.
Equipment displays should be easy to read and understand.
All controls and displays on a platform should be consistent.
All control and displays should behave in a way personnel expect.

REFERENCES

Ming, K.T., "Application of a Quality Management System Approach to Health, Safety, and Environment," Paper No. OSEA-94098, Offshore Southeast Asia 10th Conference and Exhibition, Singapore, Dec. 6-9, 1994.
Boben, M.E., and Rule, P., "Safety Management System Development in the South China Sea," Paper No. OSEA-94019, Offshore Southeast Asia 10th Conference and Exhibition, Singapore, Dec. 6-9, 1994.
Briscoe, S.J., and Wajidi, F.F., "The Origins and the Consequences of Naturally Occurring Radiation Material for the S.E. Asia Oil and Gas Industry," Paper No. OSEA-94020, Offshore Southeast Asia 10th Conference and Exhibition, Singapore, Dec. 6-9, 1994.
Brabazon, P.G., Gibson, W.H., Tinline, G., and Leathley, B.A., "Practical Applications of Human Factors Methods in Offshore Installation Design," Paper No. OSEA-94140, Offshore Southeast Asia 10th Conference and Exhibition, Singapore, Dec. 6-9, 1994.