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Document Title : Structural Integrity Assessment Template

Case Title - [Safety Case Title] COIN Numbers - [Case] / [SVC Number]Duty Holder – [Company Name] Topic Assessor – [Name]

CAP Reference – [Portal Reference]STRUCTURAL INTEGRITY ASSESSMENT TEMPLATE

Work Instructions

Topic specialists should use this template to record their assessment of the Structural Integrity aspects of a safety case. Assessment should be against the requirements of SCR2015.

Exemplar Approach - This template should be used in accordance with the scope of the Assessment Instructions when the topic is included for assessment. An exemplar approach may be sufficient if some material has been previously accepted and has not materially changed. For example a CMAPP or SEMS from an existing, accepted safety case.

The template is one of a series covering all assessment topics, which together form a complete record of the safety case assessment and create evidence of how the decision to accept the case, or not, was reached. The templates identify the specific regulatory requirements of SCR2015 for the topic and indicate what the competent authority expects to find within a safety case to demonstrate that those requirements are met. The template complements the published guidance that supports the regulations and topic sector guidance. The templates are available to promote transparency and assist duty holders in drafting submissions.

Green text indicates regulatory requirements that are new in SCR2015.Black text represents regulatory requirements that are contained in both SCR2005 and SCR2015.

Non Acceptance Issue - A Non Acceptance Issue (NAI) is a deficiency in the demonstration made within a safety case, which, if not resolved, will prevent the case from being accepted under the relevant statutory provisions. Non Acceptance Issues must be sent by a formal letters to the duty holder requiring them to be dealt with in the appropriate manner, giving the duty holder a clear understanding of how to address the deficiency. Clarification - A Clarification is an explanation provided by a duty holder on request during assessment to enable the assessing Inspectors to be confident of their interpretation of the information in a safety case. Clarifications are a routine part of assessment work and should be raised with a duty holder promptly. Clarifications do not require formal letters. Communicating by telephone and email is sufficient. A meeting between the duty holder and relevant topic specialists may also be appropriate in some circumstances for clarifications. Clarification is not a first stage before raising non-acceptance issues. Any aspect that could credibly lead to a Non-Acceptance Issue should be raised as such in the first instance.

Design or Relocation Notification - Where the template is used to aid the inspection of a Design or Relocation Notification, Inspectors should consider if the information provided meets the requirements of Schedule 5 of the regulations. The inspection must identify any Potential Non Acceptance Issues to draw to the duty holder’s attention. Reference to these requirements outlined in Sections 4 of this template may be useful when forming an opinion. A record of the inspection should be made in Section [X].

TRIM: 2019/22977 Revised: 1712/2018 of 22Owner: ED4.2 – Structural Integrity



CAP Reference – [Portal Reference]Relevant Pre-Existing Guidance

APOSC Principles:

Factual information Principle 1

The factual information should meet the SCR15 requirements and provide sufficient detail to support the arguments made in the case

Management of health and safety

Principle 2 The safety case should demonstrate that the management system is adequate to ensure compliance with the relevant statutory provisions

Principle 3 The management system should show an appropriate level of control during each phase of the installation life cycle, including design, construction, commissioning, operation, decommissioning and dismantlement

Major accident hazard identification

Principle 4 A systematic process should be used to identify all reasonably foreseeable major accident hazards that apply to the installation, together with potential initiating events or sequences of events

Major accident risk evaluation

Principle 5 The methodology and evaluation criteria adopted for major accident risk assessment should be clear

Principle 10The identification of risk reduction measures should be systematic and take into account new knowledge

Principle 11 The reasoning behind the choice of risk reduction measures to be implemented should be described. Decisions on implementation should take reasonable practicability into account

Principle 12 Risk reduction measures identified, as part of the risk assessment, should be implemented if they are reasonably practicable




CAP Reference – [Portal Reference] Principle 13

In deciding what is reasonably practicable, the case should show how relevant good practice and judgement based on sound engineering, management and human factors principles have been taken into account

Principle 14 Where remedial measures are proposed to reduce risk, the timescale for implementing them should take account of the extent of such risks and any practical issues involved

Major accident risk management

Principle 15 Measures taken to manage major accident hazards should be described

Principle 16 The safety case should explain how inherently safer design concepts have been applied in the design decisions taken

Principle 17 The measures for preventing major accident hazards should take account of the various activities undertaken during the installation's current phase of operation

Principle 18 Appropriate detection measures should be provided for any reasonably foreseeable event requiring an emergency response

Principle 19 Appropriate control and mitigation measures should be provided to protect personnel from the consequences of a major accident

Emergency response

Principle 22 The Temporary Refuge (TR) should provide sufficient protection to enable people to muster safely, to permit the emergency to be assessed, and to allow the emergency response plan to be executed

Principle 23 Criteria should exist that describe the Temporary Refuge integrity (TRI) and the time over which TRI needs to be maintained against all hazards identified in the risk assessment. The safety case should demonstrate that these criteria are met i.e. that TRI would be maintained for the necessary time




CAP Reference – [Portal Reference]

Life cycle requirements

Principle 26 A Design Notification should describe how the principles of risk evaluation and risk management are being applied to the design to ensure that major accident risks will be controlled so as to ensure compliance with the relevant statutory provisions

Combined operations

Principle 28The management system should address the additional risks associated with combined operations

Principle 29 A systematic approach should be taken to assessing the impact of combined operations on the conclusions of the operational safety case for each installation

Principle 30 A systematic approach should be taken to identifying and assessing any additional major accident hazards arising from combined operations. These can be new hazards or changes to existing hazards

Principle 32 Elements that become safety and environmental critical elements (SECEs) as a result of combined operations should be identified and made subject to verification. They may be parts of the individual installations, or additional plant or equipment provided for the combined operations

Decommissioning and dismantlement

Principle 33 When the safety case is revised to deal with decommissioning or dismantlement, the sequence of events should be described, from cessation of production to dismantling of the structure

Principle 34 The case should describe the extent and availability of safety systems during decommissioning or dismantlement

Principle 35 Any additional major accident hazards arising from decommissioning or dismantlement should be identified

Principle 36




CAP Reference – [Portal Reference]The management system should demonstrate that effective control will be maintained throughout decommissioning or dismantlement

GASCET Chapters:

2.2.1 – Structural Integrity

3.1 - Decommissioning




CAP Reference – [Portal Reference]1. Structural Integrity Requirements

a) SCR2015 Regulation 16 (1) a & b – Management and control of major accident hazards

SCR2015 Regulatory Requirement

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16.—(1) A duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraph (2), include in the safety case sufficient particulars to demonstrate that—

(a) the duty holder’s management system is adequate to ensure—(i) that the relevant statutory provisions will, in respect of matters within the duty holder’s control, be complied with; and(ii) that the management of arrangements with contractors and sub-contractors is satisfactory;

(b) the duty holder has established adequate arrangements for audit and for the making of reports of the audit;Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments

The safety case should adequately set out the:1. key structural personnel and their role within the

organisation;2. arrangements for identification of major accident

hazard control and recovery3. arrangements for auditing and monitoring the

Structural Integrity Management (SIM) system




CAP Reference – [Portal Reference]b) SCR2015 Regulation 16 (1) c,d & e – Management and control of major accident hazards


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(c) all hazards with the potential to cause a major accident have been identified;(d) all major accident risks have been evaluated, their likelihood and consequences assessed, including any environmental, meteorological

and seabed limitations on safe operations, and that suitable measures, including the selection and deployment of associated safety and environmental-critical elements have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with; and

(e) in the case of a non-production installation, all the major hazards have been identified for all operations the installation is capable of performing.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment CommentsThe safety case should demonstrate the following issues relating to the structural integrity issues have been reduced to ALARP:

1. Structural response to fire including fire protection rating to structure

2. Structural response to explosion including explosion overpressure capacity

3. Severe Weather and corresponding environmental loading including air gap

4. Foundation integrity including site specific assessment including scour.

5. Structural Integrity arrangements for the Temporary Refuge, escape and evacuation facilities

6. Weight control / structural overloading7. Vessel Impact8. Corrosion9. Fatigue assessment10. Dropped objects11. Marine growth12. Helideck capacity13. Seismic events




CAP Reference – [Portal Reference]14. Rack Phase Difference (Jack Ups)

c) SCR2015 Schedules 6 & 7 – Particulars to be included in a safety case for the operation of a production / non-production installation


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Schedule 6 Regulation 8 / Schedule 7 Regulation 7

A description of the main requirements in the specification for the design of the installation and its plant, which must include—a) any limits for safe operation or use specified therein;b) a description of how the operator has ensured, or will ensure, compliance with regulation 4 of the Offshore Installations and Wells

(Design and Construction, etc.) Regulations 1996;c) a description of how the duty holder has ensured, or will ensure, the suitability of the safety and environmental-critical elements;d) …………….e) any relevant codes, standards and guidance used in the construction and commissioning of the installation. (Note – Requirement “d” in

Schedule 7)Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments

The safety case should set out :1. the operational limits of the structure placed on it

through the design. (Refer also to the structural expectations listed against SCR15 Regulation 16 and DCR Regulation 5)

2. the codes standards and guidance used to design, construct and commission the installation and or gap analysis between current and original codes and standards

In relation to the DCR Reg 4 criteria, the safety case should demonstrate the following criteria:

a. The installation is designed to withstand reasonably foreseeable loads due to operational or environmental criteria.

b. Sufficient redundancy is built into the design to accommodate any reasonably foreseeable damage

c. Adequate arrangements are in place to maintain the integrity of the installation throughout its life cycle including fabrication




CAP Reference – [Portal Reference]d. Appropriate criteria will be used to define structural

events and matters to be reported under DCR Reg 9.

e. The design gives consideration to safe dismantlement and decommissioning of the structure.


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Particulars of—a) the limits of the environmental and meteorological conditions beyond which the installation cannot safely be stationed or operated;b) the properties of the seabed and subsoil which are necessary for the safe stationing and operation of the installation; andc) the locations in which the installation may be stationed and operated safely. (Note – Contained in Schedule 7 only)

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment CommentsThe safety case should set out:

1. The safe operating environmental and meteorological conditions for the installation. This should be based on the original design and current guidance.

Refer to table 1(b)(3)

2. The seabed and soil properties used to determine the ongoing suitability of the foundation structure.

3. Suitable operating locations or the process to determine what a suitable operating location is. (This relates more specifically to mobile installations)

Refer to table 1(b)(5) above






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A description, with suitable diagrams, of the installation, including a description of—a) the main and secondary structure of the installation and its materials;b) ……………………….

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment CommentsThe safety case should contain the following information:

1. Sufficient structural drawings of the installation to identified main structural system and design principles;

2. Details of the structural materials used along with justification of why they are suitable for use on the UKCS




CAP Reference – [Portal Reference]SCR2015 Regulatory Requirement

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Particulars of any combined operations which may involve the installation, including—

a) ……………………..b) a summary of the arrangements in place for a joint review of the safety aspects of any such combined operation by all duty holders

involved, which must include the identification of hazards with the potential to cause a major accident and the assessment of risks which may arise during any such combined operation;

c) the plant likely to be used during any such combined operation; andd) the likely impact any such combined operation may have on the installations involved.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment CommentsThe safety case should set out generically:

1. Arrangements for considering potential structural implications for either installation as a result of the combined operation

2. Nature of any combined operations which may take place?




CAP Reference – [Portal Reference]2. Structural Verification Requirements

a) SCR2015 Regulation 17(3) & 18(2) – Safety case for production installation (and non-production) installation


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The operator of a production (or owner of a non-production) installation must include with the safety case sent to the competent authority a statement, made after considering any reports or reservations of the verifier under regulation 9(2)(d), (3)(b) and (4)(c), that the record of safety and environmental-critical elements and their scheme of maintenance are or will be suitable.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment CommentsThe safety case should give sufficient detail to demonstrate the following in relation to the verification of the structural integrity of the installation

a) A verification scheme identifying the structure as a safety and environmental critical element exist

b) An independent verifier has commented on the adequacy of the verification scheme;

c) The performance standards used to ensure structural integrity.




CAP Reference – [Portal Reference]3. Dismantlement Requirements

This section of the template should only be required when considering the actual dismantlement of a fixed installation.


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a) SCR2015 Regulation 16 (1) – Management and control of major accident hazards


(a) the duty holder’s management system is adequate to ensure—(i) that the relevant statutory provisions will, in respect of matters within the duty holder’s control, be complied with; and(ii) that the management of arrangements with contractors and sub-contractors is satisfactory;

(b) the duty holder has established adequate arrangements for audit and for the making of reports of the audit;

(c) all hazards with the potential to cause a major accident have been identified;

(d) all major accident risks have been evaluated, their likelihood and consequences assessed, including any environmental, meteorological and seabed limitations on safe operations, and that suitable measures, including the selection and deployment of associated safety and environmental-critical elements have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with; and

(e) in the case of a non-production installation, all the major hazards have been identified for all operations the installation is capable of performing.

b) SCR2015 Schedule 8 – Particulars to be included in a current safety case in respect of the dismantling of a fixed installation

Regulation 5

A description of how the proposed arrangements, methods and procedures for dismantling the installation and connected pipelines take adequate account of the design and method of construction of the installation and its plant.

Regulation 6 (b)





In the case of the dismantling of a fixed production installation— (b) a description of the risks of a major accident associated with the decommissioning of the installation to workers and the environment, the total exposed population, and the risk control measures;

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments

Description of planned operations

1. Description of the proposed dismantlement plan including expected final removal date

2. Description of the processes that affects the structural SECE such as

o structural analysis summary as necessary to demonstrate sufficient integrity for the chosen dismantlement method at all stages of the dismantlement process

o details of any structural strengthening and modification work

o verification of the above modifications and supporting studies by the ICP

o confirmation of integrity for lifting and transport to the final destination

Overview of Risk Assessment Process

1. Potential dropped object risk considerations such as pipelines / subsea infrastructure on the lift / transportation path, especially if transported on




CAP Reference – [Portal Reference]hook

2. Marine warranty / assurance for transportation, weather window, HLV suitability, HLV lift capacity, transportation method

3. If leg cutting involved, assessment of the effect of any delays in the final lift

4. Assessment of the impact of leaving the installation with some or all legs in cut state into winter or indefinitely

5. Structural assessment based on the current condition and any deterioration and damage found in present and past inspection data

6. Relevant structural analysis and assessments to formulate a strategy for maintenance, from COP to final dismantlement, if the intention is to leave it unmanned for some period

7. If re-boarding is / may be required, the appropriate strategy and consideration of any preparatory work such as preparation of multiple gangway connection points, if a walk to work vessel were to be employed

8. Vessel impact considerations during the decommissioning stage and re-boarding stage, as relevant considering the vessel impact capacity of the installation

9. Installation specific considerations such as availability of pumps for drawdown in GBS after cutting legs etc.

10. Consideration of any other relevant risks not




CAP Reference – [Portal Reference]mentioned above

Control Arrangements

1. Marine procedures to control vessel impact risk

2. Re-boarding strategy and risk assessment, if applicable

3. Structural stability management throughout the dismantlement sequence considering weight and COG changes

SECE’s / Performance Standards

1. ICP involvement in the structural decommissioning & dismantlement studies and modifications

2. It is expected that Structural Integrity as a SECE remains suitable and effective until dismantled

Monitoring and Review

1. Arrangements for monitoring and review of structural integrity all through the decom process




CAP Reference – [Portal Reference]4. Design / Relocation Notification Requirements

a) SCR2015 Schedule 5 – Design / Relocation Notification Requirements


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ISchedule 5 - Particulars to be included in a design notification or a relocation notification

(2) A general description of the means by which the management system of the operator will ensure that the structure and plant of the installation will be designed, selected, constructed and commissioned in a way which will control major accident risks to comply with the relevant statutory provisions.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should set out the following:

a) A competent structural design and construction team has been appointed

b) An effective management system is in place to address all structural design and construction aspects.


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(3) A description of the design process from an initial concept to the submitted design or selection of an existing installation, the relevant standards used and the design philosophy used to guide the process.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should set out:

a) What different structural options were considered;b) Why the preferred solution was selected;c) What design standards have been used;





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Schedule 5 - Particulars to be included in a design notification or a relocation notification

(4) A description of—

(a) the chosen design concept in relation to the major hazard scenarios for the particular installation and its intended location, and the primary risk control features, including suitable diagrams, and a summary of the other design options which were considered;

(b) how the chosen design concept is intended to ensure—

(i) compliance with the requirements set out in regulations 5 (requirements as to operational integrity and composition) and 10 (integrity in dismantlement) of the Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996( ); and

(ii) that risks with the potential to cause a major accident are reduced to the lowest level that is reasonably practicable; and

(c) the criteria used to select the chosen design concept and the process by which the selection was made.Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection Comments

The design notification should set out:a) The major accident scenarios which could have an

effect on the structure and how the structure has been designed to address them:

Structural response to Fire Structural response to Explosion Structural Loading conditions Structural Response to vessel impact Corrosion Fatigue Dropped objects Marine growth Helicopter Impact Seismic events

b) How the designers allowed for the structure to be dismantled;

c) Details of the criteria used to establish the selected design concept.





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(5) A suitable plan of the intended location of the installation and of anything which may be connected to it, and particulars of—

(a) the meteorological and oceanographic conditions to which the installation may foreseeably be subject; and(b) the properties of the seabed and subsoil at its intended location..

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should set out:

a) The intended installation location;b) The meteorological and oceanographic conditions

the installation must withstand including approach to air gap;

c) The seabed and subsoil conditions.


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(6) A description of any environmental, meteorological and seabed limitations on safe operations, and the arrangements for identifying risks from seabed and marine hazards such as pipelines and the moorings of adjacent installations.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should state the maximum conditions the structure of the installation is designed to operate in.





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(7) Particulars of the types of operation, and activities in connection with an operation, which the installation is capable of performing.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should set out what operations the structural design has assumed can be carried out. This will have implications for the loads the structure is capable of carrying.


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(9) A description of the verification scheme which complies with regulation 13(1) and an initial list of the safety and environmental-critical elements and their required performance.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should set out how structural design and construction activities are addressed within the verification scheme.





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(11) Where a non-production installation is to be converted for use as a production installation, a justification demonstrating that the installation is suitable for such conversion.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should set out why the existing structure is suitable for such a conversion or what structural remedial works are require and why they are appropriate.


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(12) Where a production installation is to be moved to a new location to serve a different production operation, a demonstration that the installation is suitable for the proposed production operation..

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Inspection CommentsThe design notification should set out why the existing structure is suitable for such a to be placed in the desired new location. Particular consideration must be given to seabed, sub soil, environmental and metrological conditions as well as changes to the loadings from operational conditions.




CAP Reference – [Portal Reference]STRUCTURAL INTEGRITY REQUIREMENTS - ASSESSMENT SUMMARY

NAI – Non Acceptance Issue

SCR2015 Regulatory Requirement ClarificationRequired

NAI Required

Conclusion

1. Structural Integrity Assurance Requirementsa) SCR2015 Regulation 16 (1) a & b – Management

and control of major accident hazards

b) SCR2015 Regulation 16 (1) c, d & e – Management and control of major accident hazards

c) Schedules 6 & 7 – Particulars to be included in a safety case for the operation of a production / non-production installation

2. Structural Verification Requirementsa) Regulation 17(3) & 18(2) – Safety case for

production installation (and non-production installation

3.Dismantlement Requirementsa) SCR2015 Regulation 16 (1) a & b – Management and control of major accident hazards

b) SCR2015 Regulation 16 (1) c, d & e – Management and control of major accident hazards c) Schedule 8 – Particulars to be included in a current safety case in respect of dismantling of a fixed installation.4. Design / Relocation Notification Requirementsa) Schedule 5 – Particulars to be included in a design

notification or a relocation notification


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