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SIMULTANEOUS OPERATIONS

GUIDELINES

PETRONAS CARIGALI SDN BHD

WW ALL O 05 001

Rev 1, September 2013

Simultaneous Operations Guidelines WW ALL O 05 001 Main Table of Contents Rev 1, Sept 2013

PETRONAS CARIGALI SDN BHD Main Table of Contents

Page i

SIMULTANEOUS OPERATIONS GUIDELINES

Main Table of Contents

Preliminary Foreword

Distribution List

Amendment Summary

Abbreviations and Acronyms

Section 1 Introduction

Section 2 Roles and Responsibilities

Section 3 Hazard and Effect Management

Section 4 Simultaneous Operations

Section 5 Specific Instruction for Simultaneous Operations (SISO)

Appendices Appendix1 Specific Safety Responsibilities for Offshore Installation Manager (OIM) during Simultaneous Production and Drilling

Appendix 2 Specific Safety Responsibilities for Drilling Supervisor during Simultaneous Production and Drilling

Appendix 3 Well Interference

Appendix 4 SISO Flow Chart

Appendix 5 Manual of Permitted Operation

Simultaneous Operations Guidelines WW ALL O 05 001 Preliminary Rev 1, Sept 2013

PETRONAS CARIGALI SDN BHD Preliminary

Page ii

FOREWORD

Authority for Rev. 1 Issue

Issue Approval Issue of this document has been formally approved by:

Document Custodian The following person has been assigned as the document custodian:

Name Haslina Bt Abdullah

Reference Indicator Head

Position Head, Operations Integrity

Proprietary Information

This document contains proprietary information belonging to

PETRONAS Carigali Sdn Bhd and shall not be wholly or partially reproduced nor

disclosed without prior permission from PETRONAS Carigali Sdn Bhd.



Page iii

DISTRIBUTION LIST

Copy No. Title Location

01 CEO DPS MD-KL

02

02

02

CEO XS MD-KL

03 XHSE XD-KL

04 DHSE DD-KL

19 FIN MD-KL

20 EP-HSE MD-KL

22 PED MD-KL

23 RM MD-KL

31 SCM-CAA MD-KL

32 SP MD-KL

33 TIM MD-KL

34 PI (CHO) MD-KL

36 MO (HSE) MO

38 VO (HSE) VO

40 INO (HSE) INO

42 MAU (HSE) MAU

44 UO (HSE) UO

46 PAK (HSE) PAK

48 TO (HSE) TO

50 IRQ (HSE) IRQ

51 PM (CHO) MD-KL

53 PMO (HSE) PMO

55 SBO (HSE) SBO

57 SKO (HSE) SKO



Page iv



Page v

AMENDMENT SUMMARY

This sheet shall be completed in detail at each revision once this document has been approved.

Details shall include revision number, description and indication of which pages and paragraphs have been revised, date of revision approval, approvers title and signature.

Rev

Description

Date

Approver Title

Signature

Notes: (1) Document Holders to update Amendment Record as and when amendments / new revisions are received.

(2)

For description of amendment the Document Holder shall indicate correction, modification, and update or deletion issue.

(3)

Document Holder to enter their company reference number, sign and date the record of entry.

(4)

Where parts amendments are issued, the relevant page(s) will be identified with a lower case letter in the revision status line in the header.



Page vi

ABBREVIATIONS AND ACRONYMS

ALARP As Low As Reasonably Practicable

AGT Authorized Gas Tester

BOP Blow-Out Preventer

CSR Company Site Representative

CSO Contractor Safety Officer

CS Construction Supervisor

DPIC Designated Person In Charge

DS Drilling Supervisor

OE Operation Engineer

FOM Field Operation Manager

FMM Field Maintenance Manager

FW Fire Watcher

SOG Simultaneous Operations Guideline

HEMP Hazard and Effects Management Process

HUC Hook Up and Commissioning

JHA Job Hazard Analysis

OSC On Scene Commander

PS Production Supervisor

MS Maintenance Supervisor

OIM Offshore / Onshore Installation Manager

PTW Permit To Work

PIC Person In Charge

POB Personnel on Board

PASR Pre-Activity Safety Review

PMT Project Management Team

ROV Remote Operated Vehicle

SCSSV Surface-Controlled Subsurface Safety Valve



Page vii

SIPCON Simultaneous Production and Construction

SIPCOM Simultaneous Production and Commissioning

SIPROD Simultaneous Production and Drilling

SIMOPS Simultaneous Operations

SSV Surface Safety Valve

SISO Specific Instructions for Simultaneous Operation

TS Terminal Superintendent

UWILD Underwater Inspection In-Lieu of Dry Docking

UIM Underwater Inspection & Maintenance

WOS Work Over Supervisor

WIE Well Intervention Engineer

WIS Well Intervention Supervisor

Simultaneous Operations Guidelines WW ALL O 05 001 Introduction Rev 1, Sept 2013

PETRONAS CARIGALI SDN BHD SECTION 1 Page 1

SECTION 1


CONTENTS

Paragraph Page No.

1.1 Purpose 2

1.2 Scope 2

1.3 Simultaneous Operations 2

1.4 Documentation and Records 3



1 INTRODUCTION 1.1 Purpose

This Simultaneous Operation Guidelines defines the minimum HSE standard when carrying out non production activities concurrent with production activities onshore / offshore. Note: ‘Production activities’ refers to the handling / processing of hydrocarbon under pressure, i.e. production facility is still alive.

1.2 Scope

The requirements specified in this document shall be applicable throughout PETRONAS Carigali global operations carried out for onshore / offshore production activities including for Contractors engaged in work for the Company (all companies involved in PETRONAS Carigali global operations)

1.3 Simultaneous Operations

Simultaneous operation is defined as the conduct of the following non production activities concurrent with normal production operations:

(a) Drilling, Work Over and Well Permanent Abandonment

(b) Construction, including the associated Commissioning

Pipeline & Riser Maintenance, including tie-in of new pipeline

(c) Major Maintenance (e.g. Turnaround Maintenance,

Major Plant Modification, Tank Maintenance, etc.)

(d) Underwater Maintenance / inspection on offshore

production facilities

(e) Rigless well intervention includes coiled tubing

operations, slick line and electric line

Simultaneous operations shall be limited to two (2) concurrent operations (i.e. production and one (1) additional activity). For more than two (2) operations, higher approval according to COMPANY LOA shall be obtained.

However, before decision is made to proceed with such activities, the HSE risks shall be assessed (e.g. Pre-Activity Safety Review, Project Risk Assessment, etc.) and Specific Instructions for Simultaneous Operations (SISO) shall be



developed and approved accordingly.

1.4 Documentation and Records

All documents produced in relations to the implementation of

this guidelines e.g. Pre-Activity Safety Review (PASR)

checklist, Process Related Activity Procedure (PRAP), etc.

shall be made available at site for reference and kept for a

period of at least seven (7) years.

Simultaneous Operations Guidelines WW ALL O 05 001 Roles and Responsibilities Rev 1, Sept 2013

PETRONAS CARIGALI SDN BHD SECTION 2 Page1


ROLES AND RESPONSIBILITIES

CONTENTS

Paragraph Page No.

2.1 Introduction 2

2.2 Roles, Responsibilities and Accountabilities 2



2 ROLES AND RESPONSIBILITIES 2.1 Introduction

This section defines the roles, responsibilities and accountabilities of key personnel during the planning and execution of simultaneous operations activities. The roles, responsibilities and accountabilities of key personnel shall be fully specified in the Specific Instructions for Simultaneous Operation (SISO) to be developed for all simultaneous operations.

2.2 Roles, Responsibilities and Accountabilities

Below is the list of the key personnel that may be involved in

developing the SISO document and / or execution of the

simultaneous operations activities:

(a) Operation Engineer (b) Maintenance Engineer

(c) Drilling Engineer

(d) Construction Engineer (e) Hook-up and Commissioning Engineer (f) Well Intervention Engineer (WIE)

(g) Authorized Gas Tester (AGT)

(h) Fire Watcher (FW)

(i) Safety and Health Officer (SHO)

(j) Production Supervisor (k) Maintenance Supervisor (l) Drilling Supervisor

(m) Hook-up and Commissioning Supervisor

(n) Well Services Supervisor (WSS)

(o) Work Over Supervisor (WOS)

(p) Contractor’s Site Representative

(q) Company Site Representative (e.g. Drilling,

Construction, Diving, Hook-up and Commissioning,

Maintenance, and Well Intervention Supervisor)

(r) Onshore / Offshore Installation Manager / Terminal Superintendent

(s) Field Operation Manager

(t) Field Maintenance Manager

(u) Project Manager, Construction / Commissioning

(v) Well Intervention Manager

(w) Drilling Work Over / Superintendent

(x) Head Maintenance

(y) Head HSE Division / Country / Region

(z) Head Production



2.2.1 Operation Engineer / Maintenance Engineer

Operation, maintenance, discipline engineer (e.g. rotating equipment, well services, electrical, etc.) and project engineer shall be jointly responsible to prepare the SISO. Note: For Turnaround related activities, Turnaround Management Guide (TAMG) requirement for the preparation of Turnaround Execution Plan (TEP) shall be incorporated into SISO and only one document to be prepared.

2.2.2 Drilling Engineer

Drilling Engineer is jointly responsible to prepare the SISO with the Operation Engineer for simultaneous operations involving production and drilling.

2.2.3 Construction Engineer

Construction Engineer is jointly responsible to prepare the SISO with the Operation Engineer for simultaneous operations involving production and construction.

2.2.4 Hook-up and Commissioning Engineer

Hook-up and Commissioning Engineer is jointly responsible to prepare the SISO with the Operation Engineer for simultaneous operations involving production and hook-up and commissioning.

2.2.5 Well Intervention Engineer (WIE)

WIE is jointly responsible to prepare the SISO with the

Operation Engineer for simultaneous operations involving

production and well intervention.

2.2.6 Authorized Gas Tester (AGT)

The Authorized Gas Tester is responsible for carrying out gas testing in and around the area where any Hot Work or other designated Work is planned. For gas tests prior vessel entry tasks (for Production Malaysia only), the AGT must be certified by Department of Safety and Health (DOSH). Once satisfied, the AGT shall declare the area is safe to work in the PTW.

The AGT shall carry out periodic gas tests at the Worksite as required in the PTW and ensure that:



(a) There are adequate certified portable gas detectors

available onsite. (b) All requirements as specified in the PTW is adhered to,

prior to commencement of any spark producing work, e.g. welding, grinding, gas cutting, and etc.

2.2.7 Fire Watcher

A competent fire watcher shall be present at the worksite throughout the duration of hot work, (e.g. grinding, cutting, welding, etc.) activities.

Fire watchers, who normally can be identified e.g. by wearing the Fluorescent Vest and Red Hard Hats, shall ensure that all requirements for protection in the hot work activities are met, such as:

a) Physical barriers have been erected and safety

signages installed

b) Adequate protective covers are in place.

c) Adequate Portable Firefighting / Extinguishing Equipment are in place.

d) Fire hoses connected to portable firewater pump are in

place.

e) Continually monitor the Hot Work area activities and

ensure all sparks, hot slag and hot spots at or around

the area are kept safe or extinguished.

When Hot Work may affect other areas such as work on or close to a partition / wall, another Fire Watcher shall be stationed in that area on the other side of the partition / wall. A Fire Watcher shall be present throughout meal break times in all areas where Hot Work is ongoing. In the event of fire, the Fire Watcher is to raise the alarm, advice on the location, and extinguish the fire with the portable firefighting equipment available (if safe to do so). Fire Watcher to ensure all Hot Work are stopped and the equipment is secured in the event of platform alarm triggered.



2.2.8 Contractor’s Safety and Health Officer

The Contractor's Safety and Health Officer shall report to CSR and liaise with Work Leader (WL) for all activities. When appointed and required (project based), Contractor's Safety and Health Officer shall be available throughout the duration of Simultaneous Operations activity. The Contractor's Safety and Health Officer responsibilities are at minimum but not limited to the following: (a) POB movement supervision is carried out on the

Gangway to the Work Platform.

(b) Checking and confirming that all safety equipment onboard is adequate and certified.

(c) Conduct daily PTW audit.

(d) Continually monitor all activities to ensure that safe working practices are in place.

(e) Promote Safe & Unsafe Behavior (ACT, BOT) & Unsafe Condition reporting.

(f) Instituting follow-up action, to prevent recurrence of any unsafe act or conditions found.

(g) Attend the Daily Coordination Meeting and Shift Handover Meetings.

(h) Report to CSR on daily HSE Performance.

(i) Conduct weekly safety audit.

(j) Checking of emergency preparedness in his area

(k) Attend contractor’s daily tool box meeting 2.2.9 PCSB Safety and Health Officer (SHO)

The PCSB SHO’s responsibilities are as follows: (a) Implement Plant General Inspection program and

record

(b) Compile and update HSE statistic.

(c) Monitor and track PTW implementation and lead PTW audit



(d) Review IIR and input data into i-HSE system (if system is accessible at worksite)

(e) Conduct HSE training / awareness / program to operations and contractors

(f) Conduct Safety Briefing to visitors / incoming POB at the worksite.

(g) Plan and coordinate ER Drill / Exercise

2.2.10 Production Supervisor (PS) / Maintenance Supervisor (MS)

In addition to the normal roles and responsibilities, the PS/MS shall at a minimum but not limited to:

(a) Ensure all specific potential hazards identified in the

SISO and Job Hazard Analysis are contained to As Low As Reasonably Practicable (ALARP).

(b) Ensure that all specified safety precautions identified in the SISO, JHA and PTW are implemented.

(c) Hold kick off meeting with team to ensure positive communication of SISO.

(d) Present the SISO to all personnel onboard the work barge/platforms before commencing SISO activities

2.2.11 Drilling Supervisor (DS)

The DS's responsibilities are the following:

(a) Designated as the CSR for drilling activities. (b) Responsible for the whole drilling operations and HSE

on the drilling rig and platform and to liaise closely with the OIM / SOR / DPIC of the installation.

(c) Chair the drilling daily operation meeting and is one of the signatories for the PTW system.

(d) Designated as Authorised Supervisor in PCSB PTW system for drilling activity

(e) Manage the emergency at drilling rig and drilling platform and inform OIM / SOR / DPIC accordingly.



(f) Ensure regular emergency drills are conducted in collaboration with the OIM.

(g) Review the drafted SISO document to ensure drilling hazards and risk are assessed and controlled.

For Specific Safety Responsibilities for Drilling Supervisor during Simultaneous Production and Drilling Activity, refer to Appendix 2.

2.2.12 Hook-up and Commissioning Supervisor

Hook-up and Commissioning Supervisor is one of the SISO

reviewers for simultaneous operations involving production

and hook-up and commissioning.

2.2.13 Well Services Supervisor (WSS)

The WSS's responsibilities are the following:

(a) Designated as CSR for well intervention. (b) Attend daily platform coordination meetings and Shift

Handover Meetings.

(c) Conduct joint regular emergency drill with platform if the work boat / barge is used.

2.2.14 Work Over Supervisor (WS)

The WS's responsibilities are the following: (a) Designated as the CSR for work over activities. (b) Chair the daily Work Over Coordination Meeting and is

one of the signatories for the PTW system.

(c) Manage the emergency at work over barge / rig and to inform OIM / DPIC accordingly.

(d) Conduct joint regular emergency drill with platform.

(e) On satellite platform, WS may be appointed as approving authority for PTW related to dedicated well and to acknowledge on the PTW on platform operation related activity.



2.2.15 Contractor’s Site Representative

Contractors’ Site Representative shall be accountable to: (a) supervise and manage the implementation of the

project scope and the contractors’ compliance to safety mitigations and precautions highlighted in all safety / risk assessments of the project.

(b) Liaise with the OIM / CSR the daily progress and planned activities of the project.

2.2.16 Company Site Representative (CSR)

The Company Site Representative (CSR) is the appointed person who represents the Company and is responsible for the Company’s interest in various activities at the worksite. These activities are:

(c) Drilling / Work Over (d) Construction (e) Hook-up and Commissioning (f) Installation (g) Major Maintenance including underwater maintenance

and pipeline maintenance

The CSR's responsibilities are at minimum but not limited to the following:

(a) Carry out and supervise simultaneous operations

activities in accordance with the requirement of simultaneous operations developed for the Project.

(b) Attend & brief all personnel under direct jurisdiction of

the specific potential hazards identified in the SISO document.

(c) Implement all specified HSE precautions identified in the simultaneous operations document for a particular project.

(d) Ensure all live-lines on the Platform that have been positively isolated for the project are clearly identified and marked and protected by barriers wherever possible.

2.2.17 Onshore/Offshore Installation Manager (OIM)/ Terminal Superintendent (TS)

The Onshore / Offshore Installation Manager (OIM) / Terminal Superintendent (TS) shall be the single point accountable party for the execution of Simultaneous Operations at site. In addition to the normal roles and



responsibilities, the OIM shall at a minimum but not limited to:

(a) Manage the conduct of the simultaneous operations

activities through Permit To Work (PTW) Procedures.

(b) Implement measures for all the control and recovery

barriers identified during the risk assessment.

(c) Be the On-Scene Commander in an emergency.

(d) Communicate the SISO requirements to all site personnel.

For Specific Safety Responsibilities for Offshore Installation Manager (OIM) during Simultaneous Production and Drilling Activity, refer to Appendix 1.

2.2.18 Field Operation Manager / Field Maintenance Manager

Field Operation Manager / Field Maintenance Manager shall

be accountable to review and endorse the SISO in the field

which is under their jurisdiction.

2.2.19 Construction / Commissioning Project Manager

Construction Project Manager is the endorsing authorities for the SISO involving production and construction activities.

2.2.20 Well Intervention Manager

Well Intervention Manager is one of the endorsing authorities

for the SISO involving production and well intervention

activities.

2.2.21 Drilling / Work Over Superintendent

Drilling / Work Over Superintendent has overall

accountability for the field drilling / work over activities.

Drilling / Work Over Superintendent is one of the approving

authorities for the SISO involving production, work over and

drilling activities



2.2.22 Head Maintenance

Head Maintenance is one of the endorsing authorities for SISO involving maintenance activities under his / her jurisdiction.

2.2.23 Head HSE Division / Country / Region

Head HSE Division / Country / Region is one of the

endorsing authorities for the SISO document and is

responsible to review the HSE aspects of the SISO.

2.2.24 Head Production

Head Production shall be accountable for the overall

management of simultaneous operation and is the final

approval authority for SISO in the field which is under their

jurisdiction.

Simultaneous Operations Guidelines WW ALL O 05 001 Hazard and Effect Management Rev 1, Sept 2013


SECTION 3:


HAZARD AND EFFECTS MANAGEMENT

CONTENTS

Paragraph Page No.

3.1 Hazard and Effects Management Process (HEMP) 2

3.2 Risk Assessment 3

3.3 Risk Assessment for SISO - Key Issues and Control Barriers

4



3 HAZARD AND EFFECTS MANAGEMENT 3.1 Hazard and Effects Management Process (HEMP)

Prior to simultaneous operations, risk assessment shall be conducted and the required controls shall be identified. Risks posed by hazard associated with the conduct of simultaneous operations throughout PETRONAS Carigali, including Contractors, shall be managed to a level that is as low as reasonably practicable (ALARP). The Hazard and Effects Management Process (HEMP) is based on four (4) principles as follows:

(a) Identify hazards and effects;

(b) Assess the risks posed by the hazards, in the event of

hazard release;

(c) Identify Control measures to eliminate and / or reduce the risks; and

(d) Identify Recovery measures to mitigate and / or reduce the impact to people, environment, asset and reputation.

For qualitative assessment, PETRONAS Carigali Risk Assessment Matrix shall be used to assess the risks posed by the hazard. The matrix is as shown in Figure 1 overleaf.



L - Low Risk (GREEN) - Manage for Continuous Improvement M - Medium Risk (YELLOW) - Incorporate Risk Reduction Measures H - High Risk (AMBER) - Intolerable VH - Very High Risk (RED) - Unacceptable

Figure 1: PETRONAS Carigali HSE Risk Assessment Matrix

3.2 Risk Assessment

Prior to the implementation of identified activities concurrent with normal production operations (e.g. Simultaneous Production and Drilling activities), the following shall be carried out: (a) Robust risk assessment – for all hazards associated

with the Simultaneous Operations, adequate controls

as identified and implemented.

For process-related Simultaneous Operations the risk

assessment is also referred to as Pre-Activity Safety

Review (PASR) (e.g. during Production handover to

Drilling operation).

(b) For all simultaneous operations, Pre-Activity Safety

Review (PASR) shall be conducted, and Process-

Related Activity Procedures (PRAP) shall be

5

Severity 1 Insignificant

2 Minor

3 Moderate

4 Major

5 Catastrophic

People Slight Injury Minor Injury Major Injury Single Fatality

Multiple Fatalities

Asset Slight Damage

Minor Damage

Local Damage

Major Damage

Extensive Damage

Environment Slight Impact Minor Impact Localized Impact Major Impact Massive

Impact

Reputation Slight Impact Limited Impact

Considerable Impact

Major National Impact

Major International Impact

E Almost Certain

Happens several times per year at

location E1 E2 E3 E4 E5

D Likely

Happens several times per year in

company D1 D2 D3 D4 D5

C Possible

Incident has occurred in our

company C1 C2 C3 C4 C5

B Unlikely

Heard of incident in industry B1 B2 B3 B4 B5

A Remotely likely

to happen Never heard of in

industry A1 A2 A3 A4 A5

IMPACT

LIKELIH OOD

LIK

EL

IHO

OD



developed, defining activity / task-specific procedures

and controls required to safely execute the process-

related activities and included as part of SISO

document.

(c) Additionally, Specific Instruction for Simultaneous

Operations (SISO) shall also be developed, defining

the overall management of HSE, including emergency

management, between the various parties involve in

the SIMOPS.

3.3 Risk Assessment for SISO- Key Issues and Control Barriers

As part of risk assessment in preparation of SISO document, the following key issues / control barriers shall be considered:

(a) Single-Point Responsibility

The ultimate responsibility for the effective management of the simultaneous operations is vested with the Onshore / Offshore Installation Manager. Respective work supervisor (i.e. Production Supervisor, Drilling / Work Over Supervisor, Construction Supervisor, Well Intervention Supervisor, etc.) is responsible for the safe execution of work associated with the simultaneous operations. The Onshore / Offshore Installation Manager / TS shall work closely with the respective line supervisor and other personnel involved in the simultaneous operations.

(b) Work Supervision Adequate number of work supervisor shall be appointed to ensure safe execution of high risk task, in particular where a number of such tasks are carried out concurrently. The individual supervisor shall be responsible for ensuring the safe execution of work, including the adequacy and integrity of control barriers in his work area.

(c) Positive Isolation

Prior to the commencement of simultaneous operations, positive isolation of process hazard shall be in place for each of the simultaneous activity. As a minimum, each process hazard shall be isolated by a minimum of two independent and tested barriers.



Examples of positive isolation / double barrier concept are: Simultaneous production and drilling / work over: i. Producing well protected by Surface-Controlled

Subsurface Safety Valve (SCSSV) and Surface Safety Valve (SSV); and

ii. Well being drilled / worked overprotected by overbalanced fluid column and Blow-Out Preventer (BOP).

Simultaneous production and major maintenance: i. Producing well protected by Surface-Controlled

Subsurface Safety Valve (SCSSV) and Surface Safety Valve (SSV); and

ii. Isolation of process lines using double block and bleed, or equivalent positive isolation.

(d) Permit to Work System (PTW)

Any activities on the platform other than routine rig operations and production from wells via permanent facilities shall be controlled with a PETRONAS Carigali Permit to Work (PTW) Procedure. For activities on contractor’s facilities (e.g. tender barge, pipe laying barge, etc.) the contractor’s PTW Procedure may be used after assessment and approval by PETRONAS Carigali. The procedure as outlined in PETRONAS Carigali PTW Procedure shall be adhered to. The Offshore Installation Manager (OIM) is responsible to brief the Permit to Work procedure to all PETRONAS Carigali and Contractors supervisory personnel.

(e) Matrix of Permitted Operations (MOPO)

As part of SISO, MOPO as specified in HSE Case / CIMAH report for the facility shall be used. The Matrix of Permitted Operations (MOPO) can be prepared for the safe execution of multiple activities during the Simultaneous Operations. The MOPO shall be able to define: i. Activities that may or may not be carried out.

ii. The limit of safe operation if defenses are

reduced or removed. For example, actions shall be defined if one or more safety systems fail or



are disabled for maintenance. The systems considered shall include protection, detection, shutdown, emergency response and life saving systems.

iii. The limit of safe operations permitted during the periods of escalated risk, such as in adverse weather, limitation may be imposed on use of crane, work above the water and etc.

The SISO document shall capture the MOPO for the safe execution of the Simultaneous Operations activity. A typical MOPO is shown in Appendix 5. The benefit of using the MOPO is to facilitate the identification of potential hazards associated during the Simultaneous Operations activities. This will enable sufficient measures to be taken to control Simultaneous Operations activities.

f) Platform Shutdown and Depressurization

As part of simultaneous operations, process shutdown and depressurization are required when these activities are identified:

i. Rig-up and / or rig-down (heavy lift of rig

component)

ii. Skidding of drill floor onto drilling platform (for jack-up drilling rig)

iii. Heavy lifts over pressurized hydrocarbon systems

By shutting down and depressurization of the facilities the consequence will be minimized in the event of any incidents when performing above activities. A tubing / casing annulus is considered depressurized if the pressure in the annulus is 100 psig or less. Before pressurization of oil or gas pipeline, Technical Supervisor shall consult on the lowest pressure value that can be lower down.

g) Toolbox Meeting

Simultaneous Operations Project Toolbox Meeting shall be conducted by the Work Leader to the personnel directly involved in the Simultaneous Operations activities. Attendance shall be on a day-to-day involvement basis between Supervisors and the worker of the respective activities: Production,



Construction, Commissioning, Maintenance, Well Services and Drilling. The essential focus of the toolbox meeting shall include but not limited:

Sharing of Job Hazard Analysis (JHA) for the intended work activities and the "barriers" that identify full HSE control and recovery measures required for the activities. The control and recovery measures to be in place shall an undesirable situation occur. This shall be captured in the JHA for the intended Simultaneous Operations activity.

To communicate lesson learnt from other incidences.

To share possibilities of additional risk.

Daily Coordination Meeting to cover at a minimum

the following:

HSE issues

Operational matters

Daily progress

Conflicting activities

Plan activities

Risk associated with activities

h) Personnel on Board

The total number of personnel on board an offshore shall not exceed the allowable number based on PCSB Philosophy of Life Saving Appliances. A system shall be established to conduct and effective and speedy head count of all personnel on board during an emergency.

i. Prior to departure from the Installation, report to

their immediate Supervisor and then the Administration Office, for them to sign off of the Installation's POB System.

ii. For onshore facilities, Personnel Tracking system shall be managed in such a way that can facilitate the head count during emergencies.

i) Emergency Response

i. Emergency Alarm System



Emergency Alarm System shall be initiated upon any occurrence of emergency

ii. Emergency Response Procedure

Each facility shall have its own Emergency Response Plan (ERP). Pre-Incident Action Plan shall be developed and regular combined drill simulating various relevant emergency scenarios related to Simultaneous Operations activities shall be conducted in order to enhance the competency of the personnel to respond.

iii. Mustering Station

Mustering Station or Assembly Areas shall be clearly sign-posted and noted on the Location's Plan. The OIM shall pre-identify an Alternative Mustering Points if the designated mustering point is no longer safe. A head count will be conducted during any emergency drill or evacuation. Note: Personnel shall be briefed on the mustering station and lifeboat location on arrival.

iv. Escape Routes Escape routes shall be marked and sign-posted. They shall be kept clear of trip hazards and adequately lit at all times. Escape routes shall not pass through dangerous or hazards areas and compartments with fixed Inert gas fire extinguishing systems. Emergency Exit signs shall be positioned above doors on escape routes. A plan showing Emergency Exits and Escape Routes shall be included in the SISO document and highlighted if the simultaneous activities impaired the identified escape routes. Note: For onshore facilities, all escape routes shall be marked and sign-posted at strategic locations of the plant.

v. Fire and Safety Equipment All fire and safety equipment (e.g. fire extinguisher, life buoys, etc.) installed shall be inspected and kept in order.


PETRONAS CARIGALI SDN BHD SECTION 3

Page 9

Simultaneous Operations Guidelines WW ALL O 05 001 Simultaneous Operations Rev 1, Sept 2013


SECTION 4


SIMULTANEOUS OPERATIONS

CONTENTS

Paragraph Page No.

4.1 Introduction 2

4.2 Production and Drilling 4

4.3 Production, Construction and Commissioning 6

4.4 Production and Major Turnaround Maintenance

11

4.5 Production and Underwater Maintenance 14

4.6 Production and Rigless Well Intervention

15

4.7 Onshore Facilities 18



4 SIMULTANEOUS OPERATIONS

4.1 Introduction 4.1.1 Purpose

This section is intended to provide guidance for simultaneous activities which are carried out concurrent with normal production operations.

This document defines PETRONAS Carigali minimum requirement for each simultaneous activities.

4.1.2 Scope

This section covers simultaneous operations involving; (a) Drilling ,Work Over and Well Permanent Abandonment

(b) Construction, including the associated Commissioning,

Pipeline and Riser Maintenance including tie-in of new pipeline

(c) Major Maintenance (e.g. Turnaround Maintenance, Major Plant Modification, Tank Maintenance, etc.)

(d) Underwater maintenance / inspection on offshore production facilities

(e) Rigless well intervention includes coiled tubing operations, slick line and electric line

Simultaneous operation is defined as the conduct of the above non production activities concurrent with normal production operations on the same facilities (offshore / onshore).

4.1.3 General Safety Requirement 4.1.3.1 Communication

Daily meetings shall take place between the supervisors of the respective disciplines involved to discuss the work that will be performed, the 'barriers' that provide the basic safety, the action to take if something goes wrong and the response time required. All operations shall be performed on the basis of written, approved programs. Verbal instructions shall be minimized and always be confirmed in writing. Changes to programs can only be made with the approval and co-signature of all parties involved.



4.1.3.2 Shift Handover

A formal written handover shall be conducted at the end of daily shifts and crew change. The content of the handover shall include, but not limited to:

(a) HSE issues

(b) Current ongoing activity

(c) Pending work during shift handover

(d) Work plan for the next shift

(e) Any changes in the work nature (e.g. resources, procedure, weather condition, etc.)

(f) Constraint / issues

(g) Bypass of critical equipment

(h) PTW, where applicable

The requirements on Shift Handover is described in PETRONAS Carigali Safe Shift Operations Guideline (WW ALL O 04 016).

4.1.3.3 Lifting Operation (including heavy lifts)

Simultaneous Operations activities may require the use of lifting equipment and the following classifications are accredited to the different grades of lifting operations.

Heavy lifts are lifts that involve an overall weight of 8 metric

tonnes or more. All the equipment / material and its weight

per lift shall be identified in a master list and shall be

appended in SISO document. PTW lifting certificate shall be

approved before the heavy lift operation.

Lifting operations at night are subject to approving authority’s

(OIM / TS / DS / WS / WIS / CSR) discretion based on

visibility, weather, etc.

Note: Lifting operations even those below 8 metric tonnes, can be stopped if it is deemed unsafe to proceed due to sea state, surrounding equipment, etc. by any Supervisor involved on the Simultaneous Operations Project.



4.1.3.4 Disputes

In case of disagreement between the related parties at worksite, Stop Work Policy shall be imposed and affected activities shall be secured. The said dispute shall be referred to the relevant subject matter expert or Technical Authority for resolution before resuming the activities.

4.2 Simultaneous Production and Drilling / Work Over 4.2.1 Preparation for Simultaneous Operation

In preparation for Simultaneous Operation involving production and drilling, OIM shall perform the specific safety requirement as outlined in Appendix 1 - Specific Safety Responsibilities for Offshore Installation Manager (OIM) during Simultaneous Production and Drilling Activities.

4.2.2 Areas of Consideration during Rig Activities

(a) The integrity of the well barriers.

The integrity of the well barriers are affected when there is a leak in the well (e.g. tubing string, completion accessory, packer or plug / tool), which is indicated by pressure build up on one of the annuli or the tubing head. (b) The integrity of the surface production system

The surface production system includes equipment such as a permanent test separator, sump, riser, vent facilities, flow lines, gas lift lines, depressurization line and the pneumatic / hydraulic control system. (c) The operational integrity of the ESD system. The main risks associated with the surface production system are malfunction or leakage to the atmosphere as a result of impact damage and aggravation of the general situation in case of a fire. Specific operational procedures and impact resistant floors reduce the probability of impact damage, while the ESD system limits the hazards of leakage and fire.

(d) Pneumatic system

For simultaneous production and drilling, instrument gas system shall be converted to instrument air. This is to ensure that the instrument air system used by the rig and the



instrument gas system used on the platform does not introduce additional risks due to possible communication between the air and gas system. At any time if any of the above conditions cannot be fulfilled during the simultaneous operation Stop Work Policy shall be imposed. Stop Work Policy will only be revoked after rectification and the simultaneous operation can be resumed.

4.2.3 General Precautions / Constraints for Simultaneous Operations

Simultaneous production and drilling / work over activities shall not proceed, unless:

(a) The drilling / work over activities are protected by a

minimum of two independent barriers.

(b) The production wells are protected by a minimum of two independent barriers.

(c) The integrity of the surface production system is not jeopardized by drilling / work over activities.

(d) The fixed fire water system (fire main) is operational. If fixed fire water system is not available on the platform, a temporary system shall be provided during the duration of the simultaneous operations.

(e) All escape routes are available as per Risk Assessment.

4.2.4 Well Allocation

The well shall be allocated to the Supervisor who has the primary responsibility for the operations on the well. Therefore, the well visited by the rig is allocated to the Drilling Supervisor, while the other wells on the platform are allocated to the OIM. Changes of allocation, or handovers shall be identified in the programs and shall be accompanied with a written hand over report which provides essential status details of the well (if not adequately covered by the programme), reason for the handover, and signatures of the relevant supervisors. Signature of the receiving supervisor on the hand over report implies that he has been adequately briefed about the status of the well, and he accepts the well. Handover to the OIM usually takes place after installation and testing of the Xmas tree and if applicable, after displacing the well to diesel oil.



Handover to the Drilling Supervisor for work over operations usually takes place after plugging the well below the production packer, and inflow testing of the plug.

4.3 Simultaneous Production and Construction

4.3.1 Simultaneous Production and Construction including Commissioning

This section covers construction activities that may be carried out simultaneously with the production operation. Some of the construction activities are described below: (a) Host tie-in (e.g. riser installation, receiver facilities)

(b) Major construction activity e.g. Installation of new

module, deck extension and structural replacement.

(c) Blasting and Painting

For simultaneous production and construction / commissioning, production and major maintenance, production and pipeline maintenance, in particular where hot work in hazardous area is being carried out, instrument gas system shall be converted to instrument air. This is to minimize presence of hydrocarbon gas which may result in fire explosion.

4.3.1.1 Safety Control Barriers

In carrying out simultaneous production and any of the above, the following barriers may be required;

4.3.1.1.1 Gas Test

Gas test shall be carried out continuously during hot-work activity (e.g. welding, grinding, gas cutting) by an Authorized Gas Tester (AGT) by using a certified gas detector. Authorized Gas Tester (AGT) shall be ready at worksite at all times during the activity.

4.3.1.1.2 Sparks Protection / Barricade

The area shall be protected with appropriate sparks protection (e.g. wet fire blanket, wall & wet base plate) to ensure that no sparks will fly-off from the work area. The task shall be stopped immediately if there is any damage to the sparks protection equipment.



4.3.1.1.3 Fire Fighting Equipment

Firefighting equipment (e.g. fire monitor, fire extinguisher, fire blanket, BA set, etc.) shall be at site and are in a good condition and tested.

4.3.1.1.4 Fire Watcher

A dedicated competent person as a fire watcher shall be assigned to monitor the hot work activity at all times. He shall continuously coordinate with the person who is doing the hot work and ensure all sparks & hot slag are contained within the work site.

4.3.1.1.5 Pressurized Habitat

A proper pressurized habitat shall be provided for any hot work conducted in Zone 2. Air blower & air eductor shall be installed for continuous ventilation, and removal of welding fume. A proper assessment shall be made on the source of air intake. A periodic positive pressure 0.25 mbarg to 0.5 mbarg (0.1 "to 0.2"wg) monitoring inside the pressurized habitat shall be performed and recorded.

4.3.1.1.6 Plumber Plug

Plumber plug shall be installed into existing open deck drain within 5 meter radius of any spark producing work as a precaution to prevent hydrocarbon fumes from escaping through the open drain. A wet fire blanket shall be used to cover the open drain to prevent any object or cutting & welding sparks from falling into it.

To prevent ingress of hydrocarbon from the sump caisson to the hot work area on the platform the drain line to the sump caisson shall be positively isolated by spectacle blind at the sump caisson. Additional checks shall be carried out for sump system for accidental ingress of free oil or hazardous material. Drip pans shall be used to contain it if necessary.

4.3.1.1.7 Fire Blanket

A fire blanket conforming to industry standard (BSXX) shall

be used to cover equipment and to protect facilities

whenever hot work in hazardous location is carried out. The

fire blanket shall be kept wet during hot work activities.



The minimum physical requirements of fire blanket shall; (a) Not allow welding spark to penetrate

(b) Cause welding spark to adhere rather than bounce off

(c) Be made of a material which does not burn

(d) Be of tight enough weave that welding flash does not penetrate

(e) Be sufficient in size that equipment can be adequately protected

(f) Must be properly secured not to be easily blown away by wind.

4.3.1.1.8 Isolation and Spading

All process equipment shall be positively isolated using spades and blinds. A comprehensive spading list shall be prepared and used during the isolation process and subsequent reinstatement of the process.

Only a properly installed spades and blinds can be considered as a mean of positive isolation. The procedure for installing spades, spectacle blinds, and blind flanges may take place in a condition where the system is not fully positively isolated, so extreme caution and strict adherence to the Permit to Work system conditions and precautions shall be adhered to. The use of the spectacle blinds shall be incorporated into the Spading Plan of the design package wherever positive isolation is required for Simultaneous Operations work activities. Effective mechanical isolations can include, in order of preference: (a) 1. two (2) singleblock valve in series closed, tagged

and locked (where possible), with one (1) intervening single-block vent valve open to atmosphere, tagged and locked (where possible);

(b) one (1) double-block-and-bleed valve closed, tagged

and locked (where possible) with cavity bleed valve open vent to atmosphere;

(c) one (1) single-block valve closed, tagged and locked (where possible).



Double block and bleed valves, will be considered as 'Acceptable', only after 'Proving' the line. The valves shall be 'Tagged' to indicate the reason for closure. They shall be padlocked after closure or have their hand wheels removed. The 'Proving' of isolation by valves may involve;

(d) The use of pressure gauges to indicate passing

valves; the gauges shall be verified to indicate zero pressure to reinstate the line.

(e) The use of vents and drains; the opening of the vent and drain valves shall be verified to indicate no hydrocarbon discharge and to prevent gas blowby.

Authorization shall be obtained from the OIM / TS to remove isolation valves padlock, or reinstate the removed valve hand wheel.

In view of the different nature of requirements, the isolation plan for construction or maintenance or commissioning (offshore / onshore) shall comply with Energy Isolation Procedure (WW ALL S 04 018) and detailed in the SISO Document. The OIM/TS shall have the overall responsibility for the installation and removal of positive isolation spades. The Construction Supervisor (Contractor’s) and CSR are responsible for the implementation of spading plan.

All parties including OIM/TS, WL, CSR, Contractor Construction Superintendent and project engineer shall review the marked up spading, blinding, and isolation, P&ID's provided in the Work package.

Prior to the reintroduction of hydrocarbon into this line or vessel, the following checks shall be made to confirm:

(a) Purging with inert gas.

(b) All the spades have been removed.

(c) All flanged joints that have been worked on are

securely bolted up.

(d) All bleed off valves are properly closed.

(e) All valves are lined up in the correct position.

(f) All spectacle blinds are returned to original position.

(g) All hydrocarbon process piping had been drained-off of hydrotest-water, air-dried and positively checked to be Oxygen-free.



4.3.1.1.9 Safety Signage and Barricading Tape

Adequate safety signage shall be prominently displayed to warn against hazards present. Barricading tape shall be used as required.

4.3.2 Simultaneous Production and Commissioning

This section covers commissioning activities that may be carried out simultaneously with the production operation. Commissioning is the functional and performance testing of some of the following equipment and system to ensure compliance with design specifications before handing over the equipment and facility to Operations. (a) Mechanical equipment, and associated vessels and

systems.

(b) Electrical systems.

(c) Instrumentation and control systems.

(d) Safety and firefighting systems.

4.3.2.1 Safety Control Barriers

In carrying out simultaneous production and any commissioning activities, the following control barriers but not limited to, shall be required / in place; (a) Approved Commissioning Procedures including

commissioning checklist

(b) Operating Parameters

(c) Competent Commissioning Engineer / crew

(d) Equipment / System Operating Manual

(e) Pre-Activity Safety Review Checklist

(f) MOC, if required

(g) Chemical Safety Data Sheet (CSDS), if required



4.3.2.2 Gas Test

Gas test shall be carried out periodically to check for leaks / presence of hydrocarbon by an Authorized Gas Tester (AGT) by using a certified gas detector.

4.3.2.3 Barricade

The area shall be barricaded appropriately with adequate signage to prevent unauthorized entry.

4.3.2.4 Fire Fighting Equipment

Firefighting equipment (e.g. fire monitor, fire extinguisher, fire blanket, BA set, etc.) shall be at site and are in a good condition and tested.

4.3.2.5 Pre-commissioning / Start-up

Prior to commissioning / start-up, the following checks shall be made to confirm:

(a) All the spades have been removed.

(b) All flanged joints that have been worked on are

securely bolted up. (c) All bleed off valves are properly closed. (d) All valves are lined up in the correct position. (e) All spectacle blinds are returned to original position.

4.4 Production and Major Turnaround Maintenance Major Turnaround Maintenance activities include the following but not limited to:

(a) Topside maintenance (b) Blasting and Painting (c) Pipeline and Riser Maintenance (e.g. pipeline

clamping, pipeline replacement, etc.) (d) Vessel Cleaning and Inspection

4.4.1 Safety Control Barriers

In carrying out simultaneous production and any of the above, the following barriers may be required, but not limited to:



4.4.1.1 Gas Test

Gas test shall be carried out continuously during topside hot-work activities (e.g. welding, grinding, gas cutting) by an Authorized Gas Tester (AGT) by using a certified gas detector. Authorized Gas Tester (AGT) shall be ready at worksite at all times during the activity.

4.4.1.2 Sparks Protection / Barricade

The area shall be protected with appropriate sparks protection (e.g. wet fire blanket, wall & wet base plate) to ensure that no sparks will fly-off from the work area. The task shall be stopped immediately if there is any damage to the sparks protection equipment.

4.4.1.3 Fire Fighting Equipment

Fire fighting equipment (e.g. fire monitor, fire extinguisher, fire blanket, BA set, etc.) shall be at site and are in a good condition and tested.

4.4.1.4 Fire Watcher

A dedicated competent person as a fire watcher shall be assigned to monitor the topside hot work activity at all times. He shall continuously coordinate with the person who is doing the topside hot work and ensure all sparks & hot slag are contained within the work site.

4.4.1.5 Pressurized Habitat

A proper pressurized habitat shall be provided for any hot work conducted in Zone 2. Air blower & air eductor shall be installed for continuous ventilation, and removal of welding fume. A proper assessment shall be made on the source of air intake. A periodic positive pressure monitoring 0.25 mbarg to 0.5 mbarg (0.1 "to 0.2"wg) inside the pressurized habitat shall be performed and recorded.

4.4.1.6 Plumber Plug

Plumber plug shall be installed into existing open deck drain within 5 meter radius of any spark producing work as a precaution to prevent hydrocarbon fumes from escaping through the open drain. A wet fire blanket shall be used to cover the open drain to prevent any object or cutting & welding sparks from falling into it.



4.4.1.7 Fire Blanket

An approved fire blanket shall be used to cover equipment and to protect facilities whenever hot work in hazardous location is carried out.

The minimum physical requirements of fire blanket shall:

(a) Not allow welding spark to penetrate

(b) Cause welding spark to adhere rather than bounce off

(c) Be made of a material which does not burn

(d) Be of tight enough weave that welding flash does not penetrate

(e) Be sufficient in size that equipment can be adequately protected

(f) Must be properly secured not to be easily blown away by wind.

4.4.1.8 Isolation and Spading

Only a properly installed spades and blinds can be considered as a mean of positive isolation. The procedure for installing spades, spectacle blinds, and blind flanges may take place in a condition where the system is not fully positively isolated, so extreme caution and strict adherence to the Permit to Work system conditions and precautions shall be adhered to.

The use of the spectacle blinds shall be incorporated into the Spading Plan of the design package wherever positive isolation is required for Simultaneous Operations work activities.

Double block and bleed valves, will be considered as 'Acceptable', only after 'Proving' the line. The valves shall be 'Tagged' to indicate the reason for closure. They shall be padlocked after closure or have their hand wheels removed. The 'Proving' of isolation by valves may involve:

(a) The use of pressure gauges to indicate passing valves;

the gauges shall be verified to indicate zero pressure. (b) The use of vents and drains; the opening of the vent

and drain valves shall be verified to indicate no hydrocarbon discharge.



Authorization shall be obtained from the OIM to remove isolation valves padlock, or reinstate the removed valve hand wheel. In view of the different nature of requirements, the isolation plan for construction or maintenance or commissioning (offshore / onshore) shall be detailed in the SISO Document. The OIM shall have the overall responsibility for the installation and removal of positive isolation production spades. The CS is responsible for the implementation of construction spades. All parties including OIM , WL, CS, Contractor Construction Superintendent and project engineer shall review the marked up spading, blinding, and isolation, P&ID's provided in the Work package. Prior to the reintroduction of hydrocarbon into this line or vessel, the following checks shall be made to confirm:

(a) All the spades have been removed. (b) All flanged joints that have been worked on are

securely bolted up.

(c) All bleed off valves are properly closed. (d) All valves are lined up in the correct position. (e) All spectacle blinds are returned to original position.

4.5 Simultaneous Production and Underwater Maintenance

Underwater Maintenance is defined as any Maintenance Work carried out from the Splash zone to the bottom of the structure and the area in the vicinity of the Installation, including pipelines.

Types of Work carried out under this category are inclusive of, but not limited to the following:

(a) Pipeline and Riser Maintenance (e.g. pipeline

clamping, pipeline replacement, etc.)

(b) Diving Operation

(c) Underwater Inspection In-Lieu of Dry Docking (UWILD)

(d) Remote Operated Vehicle (ROV) Operation

Precautions to be taken during the execution of underwater activities:



(a) Fire water pump shall be disabled (i.e. put on manual)

therefore no hot work shall be allowed on the platform during the period. A risk assessment shall be conducted to identify the hazard of disabling the fire water pump, and proper control and recovery barriers are in place.

(b) Rig up or rig down of scaffolding overboard shall not be allowed

(c) Sump pump shall not be operated

(d) Any aloft activities, i.e. no work outside the handrail, shall not be allowed.

(e) Sea water pump shall be put on manual mode

4.6 PRODUCTION AND RIGLESS WELL INTERVENTION 4.6.1 RIGLESS WELL INTERVENTION ACTIVITIES 4.6.1.1 Scope

The purpose of this subsection is to cover well intervention activities including slickline, electric line and coiled tubing operation which are performed without rig that are carried out simultaneously with the production operation. The activities involve primarily those of well intervention as per Wellbore Risk Management (WRM) Manual and PETRONAS Procedure and Guideline for Upstream Activities (PPGUA).

4.6.1.2 Area of Consideration

All non-rig assisted wireline work shall be subject to a Permit To Work (PTW) procedure. The well shall be isolated from the main platform ESD system and the SCSSV line shall be connected before handing over for wireline operation and shall be remotely operated using independent wellhead control panel provided by the wireline contractor. Ensure SSV is kept in open position during well intervention e.g. using Fusible Cap. The use of Blank Cap shall be strictly prohibited at any time during well intervention operations. All wireline power packs used during operations shall be classified for use in Zone 2 areas as specified in API RP 500B.



4.6.1.2.1 Additional Precautions / Constraints during Coiled Tubing Activities

The following precautions / constraints shall be followed in preparing well programs:

(a) All equipment shall be certified prior to mob to location

(b) All pressurized line and hoses shall be secured while

pressure testing a CTU

(c) Sufficient lighting shall be provided on site if Coiled Tubing work has to be done during the night/dark hours.

(d) The CTU shall be rigged up according to the procedures specified in the Specific Instructions for Simultaneous Operations (SISO).

(e) The injector head assembly shall be fixed directly over

the wellhead on a support frame.

(f) There should not be any direct load on the well grating. Preferably to use load plates or box section support frame.

(g) The hydraulic power pack motor shall be shut down when connecting the hydraulic hoses to the injector head, to prevent accidental energizing of any of the hydraulic functions of the injector head.

(h) All persons climbing to reach the injector head shall use properly secured ladders, or fall protection for safe access. Climbing on the wellhead, which may be slippery with oil, is forbidden.

4.6.1.3 Approval Level for Simultaneous Well Interventions Operation 4.6.1.3.1 DRI Regional Peer Reviews and Drilling Review Committee (DRC)

PCSB internal process shall be followed to review and endorse all the essential inputs with regards to the technical, operational and commercial aspects of ALL well intervention work plan to ensure safe & optimum process. All the simultaneous well intervention operation must be presented in respective regional peer reviews or to DRC-I as recommended by the Regional Peer Reviews for their endorsements for execution.



4.6.1.4 Additional Precaution during Emergency

For simultaneous operations PCSB Well Services Supervisor (WSS) shall prepare and agree on a Safety &Emergency Evacuation Plan. This plan shall be made known to all personnel, and posted at strategic locations on the Platform. Emergency Drill covering the work boat / barge and the Platform shall be conducted according to this plan. The specific on-site emergency procedures for the Workboat shall be prepared by the Workboat contractor and to be joined-review and agreed by both parties (PCSB and contractor).

4.6.1.4.1 Securing of Production Activity

Shut in well by closing SSV and SCSSV. When it can be safely open, as per approval from the WIS and the Offshore Installation Manager (OIM) / DPIC, the casing / tubing annulus of all wells shall be manually depressurized. Tubing / casing annulus is considered depressurized if the pressure in the annulus is 100 psig or less. Refer to Attachment Procedure carrying out ESD.

4.6.1.4.2 Securing of CTU Activities

For CTU Catenary, in case of workboat’s emergency pull out, the emergency disconnect on the Catenary Unit will allow the tubing to be cut at the coil feeder to ensure safe securing at the workboat.

4.6.1.4.3 Securing of Wireline Activities

Wireline operations in a live well shall be secured by retrieving the tool string, setting the SCSSV (if wireline retrieval), closing the SCSSV (if tubing retrievable) or a wireline plug and closing the Xmas tree valves. When working in a dead well, the tool string shall be pulled inside the lubricator and the Xmas tree valves shall be closed.



4.6.1.4.4 Workboat Emergency Pullout Procedure

The procedure for pulling out the workboat in any emergency situation such as adverse weather condition, uncontrolled CTU operation, and platform abandonment or when deemed necessary by OIM / WS shall be incorporated in the SISO document. Some of the criteria to be included but not limited to:

(a) Work Barge / Boat Master shall advise WIS and

commence to clear the gangway and heave up Anchors.

(b) Ensure tension on anchors to be paid-out to be kept at

a minimum but not in slack condition.

(c) Anchor Handling Tug (AHT) shall be called in to assist

concurrently until clear from platform

(d) Vessel shall continue to pullout until deemed safe from the platform.

(e) Master has overriding authority in matter concerning

safety, safety of life and safety of equipment on the vessel.

4.7 Onshore Facilities

Simultaneous Operations activities for onshore facilities will be similar to those for offshore facilities in terms of planning, hazard and safety management except that;

(a) No offshore rig or barge involved.

(b) There are movements of articulated vehicles (e.g.

cranes, motor vehicles, etc.)

(c) Project planning may be shorter as it does not involve offshore logistic.

(d) Emergency Drill to correspond to onshore scenarios.

(e) No multiple activities involving drilling and well services in close proximity.

(f) Impact on surrounding areas and involvement of community shall be considered.

Simultaneous Operations Guidelines WW ALL O 05 001 Specific Instruction for Simultaneous Operations (SISO) Rev 1, Sept 2013


SECTION 5


SPECIFIC INSTRUCTION FOR SIMULTANEOUS OPERATIONS (SISO)

CONTENTS

Paragraph Page No.

5.1 Introduction 2

5.2 Preparation of SISO 2

5.3 The Content of SISO 2

5.4 Approval of SISO 3

5.5 Deviation 4

5.6 On Site Verification 5



5 SPECIFIC INSTRUCTION FOR SIMULTANEOUS OPERATIONS (SISO) 5.1 Introduction

For every Simultaneous Operations, a SISO document shall be developed and approved to ensure full HSE compliance. The approved SISO document shall be shared and communicated to the work force before the work starts. If there are any changes or amendment to the approved SISO document, a written authorization / approval from the original signatories shall be obtained and added as an addendum to the original SISO document.

5.2 Preparation of SISO

Separate SISO document shall be developed for each of the Simultaneous Operations in full knowledge of all parties involved.

The SISO document shall highlight hierarchy of authority as well as the links and interface with all the other executing parties involved in the Simultaneous Operations activities.

5.3 The Content of SISO

The content of SISO for each individual Simultaneous Operations activity shall include, but not limited to the following:

(a) Introduction - Describing the facility where

Simultaneous Operations activity to be performed.

(b) Workscope- Describing the scope of work to be executed.

(c) Work Schedule including detail activities and duration.

(d) Approved Lifting Plan, if applicable.

(e) Resources – Manpower (with the right competency for critical position), role and responsibilities, and equipment to be used, etc.

(f) Hazard and Effect Management - Specifying the risk associated in the Simultaneous Operations activity and measures to control. It also highlights special precautions pertinent to the Simultaneous Operations visit.

(g) HSE Target and Plan - Describing the related Key Performance Indicator (KPI) both reactive (e.g. TRCF,



FIF,etc.) and proactive (e.g. audit, UA/UC reporting, inspection, etc.), HSE programs (e.g. bulletin, promotion, campaign, etc.)

(h) Organization (e.g. SHO, CSR, safety supervisor, inspector, etc.).

(i) Emergency Response Plan including incident notification process flow and relevant contact number.

(j) Environmental Management - To include waste management and oil spill recovery plan.

(k) Government / authority approval, if required (e.g. PTI, Domestic Shipping License, etc.).

(l) Site Specific Procedure / Work package.

(m) Attachment -Drawings (e.g. P&IDs, schematics and isometric drawings), location maps, anchor pattern, structure plans.

5.4 Approval of SISO

All SISO document shall be approved prior to the execution of the Simultaneous Operations activities. The approving authorities of SISO shall refer to the following table: (a) Drilling and Work over

(b) Construction, including the associated Commissioning

Pipeline & Riser Maintenance, including tie-in of new pipe line

(c) Major Maintenance (e.g. Turnaround Maintenance,

Major Plant Modification, Tank Maintenance, etc.)

(d) Underwater Maintenance on offshore production

facilities

(e) Rigless well intervention includes coiled tubing

operations, slick line and electric line



No. Description Prepare Review Endorse Approve

1

Simultaneous

Production And

Drilling

Drilling/Work

Over Engineer

and Operation

Engineer

OIM and Drilling

Supervisor,

By All (FM,

XSE) and Drilling/ Work Over Supt.

Production

Manager and

Drilling/Work Over

Manager

2 Simultaneous

Production And Construction

Construction Engineer and

Operation Engineer

By All (XME 1, OE, OIM)

By All (XME,

FM, XSE)

Production Manager and

Project Manager

3

Simultaneous Production And Commissioning

SISO (by PMT / OD)

Engineer In Charge

By All (XME, OE,

OIM)

By All (FM, XSE)

Production Manager and OD Project Manager

SISO (by DD) Hook Up and / or Commissioning

Engineer

By All (HUC Supervisor, OE, OIM )

By All (FM, XSE)

Production Manager and DD Project Manager

4

Simultaneous Production And Wireline / Coil Tubing Unit

(CTU)

Well Intervention Engineer

OIM and Well

Intervention TP

By All,(Well Interventi

on Manager,FM, XSE)

Production Manager

Table 5.1 Summary of Roles and Responsibilities for SISO document

Note:

XRM: Regional Reliability and Maintenance Department

XSE: Regional HSE Department

XWI: Regional Well Intervention Department



5.5 Deviation

The Simultaneous Operations activity is limited to those aspects relevant for a particular visit, and as such, other PETRONAS Carigali Procedure / Guidelines for other activities remain valid. If a conflict exists, then it shall be discussed, justified and resolved on a case-by-case basis during the preparation of Specific Instruction for Simultaneous Operations (SISO). Any deviation from the Simultaneous Operations activity shall be highlighted in the SISO document. SISO document shall be the governing document during Simultaneous Operations. All risk shall be assessed and documented accordingly using tools such as Hazard and Effect Register (HER), Job Hazard Analysis (JHA), etc. The recommended solution shall then be justified and approved by the original signatories. For clarity, the variation shall be supported by illustration, sketches or drawing.

5.6 On Site Verification

All deviations identified in the SISO shall be verified and approved by OIM / TS. The deviation requirements in the SISO shall be documented.

Simultaneous Operations Guidelines WW ALL O 05 001 Appendices Rev 1, Sept 2013

PETRONAS CARIGALI SDN BHD Appendix Page1

APPENDICES

CONTENTS

Appendix Page No.

Appendix 1

Specific Safety Responsibilities for Offshore Installation Manager (OIM) during Simultaneous Production and Drilling Activity

A1-1

Appendix 2

Specific Safety Responsibilities for Drilling Supervisor during Production and Drilling

A2-1

Appendix 3

Well Interference A3-1

Appendix 4

SISO Flowchart and Matrix of Permitted Operations (MOPO) A4-1


PETRONAS CARIGALI SDN BHD Appendix

PageA1-1

Appendix 1

SPECIFIC SAFETY RESPONSIBILITIES FOR OFFSHORE INSTALLATION MANAGER (OIM) DURING SIMULTANEOUS PRODUCTION AND DRILLING ACTIVITY

1 Prior To Moving Rig On Platform

1.1 Review all safety device inspection requirements, and conduct routine inspections on surface and subsurface valves.

1.1 Perform any other routine inspection and tests required during drilling phase that can be

performed prior to rig move.

1.2 Assist and co-ordinate with construction group any modification, relocation or removal of production equipment required to accommodate drilling rig that can be performed prior to rig move.

1.4 Check the following:

a) Platform ESD and fire and gas detection system operates properly and is in service.

b) Platform drains and drip pans are open and free of oil, trash and debris.

c) Automatic drains operate properly (if available).

d) Portable fire extinguishers are in proper location and required inspections have been performed.

e) Fire water system operates properly.

f) ESD gas detector and fire fighting system drawings are posted.

g) Navigational aids operate properly.

h) Platform hoisting equipment is operable and has been inspected and undergone preventive maintenance (particularly limit switches, swing circle bolts and hoisting ropes).

i) Schedule supervision for rig move, rig-up and other critical phases of operation.

j) Check survival craft and life raft capacities against maximum number of personnel anticipated on platform during drilling and completion phases. Survival craft and life raft capacities shall comply with PCSB life saving appliances philosophy.

k) Notify Drilling Supervisor that platform wells have been shut in and made safe; i.e., casing annuli and production tubing pressure of all wells had been bled down to 100 psig or lower, before move on / off platform commence.

l) Complete pre-move check list.


PETRONAS CARIGALI SDN BHD Appendix

PageA1-2

2 During Drilling / Workover Phase

2.1 Conduct daily co-ordination meeting with Drilling Supervisor to co-ordinate safe conduct of planned activity.

2.2 Review with Drilling Supervisor status of field transportation and evacuation plan. 2.3 Conduct the followings:

a) Evacuation and/or emergency drills (minimum twice a month).

b) Survival craft drill when weather permitting.


PETRONAS CARIGALI SDN BHD Appendix 1

Page A1-3

PRE-MOVE CHECK LIST

INSTRUCTIONS

The Checklist below should be completed by the Offshore Installation Manager (OIM) and discussed

with the Drilling Supervisor at their meeting prior to the drilling rig move onto the platform. Each should

sign the form acknowledging its completion.

Note: For details of pre-move checklist to be used as a guide, please refer to Carigali Drilling Checklist 27

1 Platform ESD and fire and gas detection system operates properly and is in service

2 Platform drains and drip pans are open and free of oil and trash.

3 Automatic drains operate properly (if available).

4 Portable fire extinguishers are in proper location and required inspections have been performed.

5 Fire water system operates properly.

6 ESD, gas detector and fire fighting system drawings are posted.

7 Navigational aids operate properly.

8 Platform hoisting equipment is operable and has been inspected and undergone preventive maintenance (particularly limit switches, swing circle bolts and hoisting ropes).

9 Give the Drilling Supervisor a schedule of performance tests or inspections on platform / well safety equipment which will be performed by production during the drilling phase.

10 Survival craft and life raft capacities can accommodate maximum number of personnel anticipated on platform during drilling and completion and workover phases.

11 Medical equipment and stocks are property labeled and maintained.

12 Helicopter "landing/take off" procedures are implemented.

13 Platform structural integrity assessment carried out

14 Subsea lines and control cables location marked for safe anchoring or vessel movement.

15 All wells are shut-in and been made safe

16 Production platforms had been converted to SIPROD mode

OFFSHORE INSTALLATION MANAGER (OIM) DRILLING SUPERVISOR

PLATFORM: DATE:


PETRONAS CARIGALI SDN BHD Appendix 2 Page A2-1

Appendix 2 SPECIFIC SAFETY RESPONSIBILITIES FOR DRILLING SUPERVISOR DURING DRILLING AND PRODUCING ACTIVITY

1 Prior To Moving Rig On Platform

1.1 Conduct on-site check of rig equipment layout and arrange for any further modification or relocation of rig or production equipment.

1.2 Meet with Offshore Installation Manager (OIM) to confirm that action required on pre-move

check list has been completed. Document meeting on first daily report and sign check list. 1.3 Review with Offshore Installation Manager (OIM) the schedule for rig move and co-ordinate

platform shut-in while rig is being moved on to platform.

2 During Drilling / Work Over Phase

2.1 Discuss evacuation plans, location of safety and firefighting equipment, smoking rules and other safety procedures with ail contract and company personnel as they come on board and sign-in.

2.2 Conduct daily check for the following:

a) Offshore Installation Manager (OIM) must ensure that the Platform safety system is in service.

b) ESD on rig floor operates properly.

c) Rig drains and drip pans are open and free of obstruction.

d) Automatic drains operate properly (if available).

e) Portable fire extinguishers on rig are in proper location and have not been discharged.

f) Production and drilling rig decks are free of oil, mud and trash.

g) Escape routes from rig and platform work areas and from quarters are unobstructed and boundaries adequately marked.

h) Navigation aids operate properly.

i) Grating, railing, walking surfaces are in good condition and other possible safety hazards on rig and platform are removed.

2.3 Conduct weekly check for the following:

a) The drilling rig fire water pumps operate properly: report action to Offshore Installation Manager (OIM).

b) Fire fighting system drawings are posted.



c) Rig lifesaving appliances (survival craft, life rafts, ring buoys, etc.) are in proper location and in good operating condition.

d) Welders are familiar with Hot Work permit procedures.

e) Breathing apparatus and Proximity Suits are readily available on rig floor. Rig hoisting equipment is operable and has received required inspections and maintenance.



Appendix 3

WELL INTERFERENCE

This Appendix describes the precautions to be followed if a well is being drilled in close proximity to

other wells. Carigali Drilling Standard Section 11.3 and Carigali Drilling Guidelines Section 3.7 on

Collision Avoidance shall be referred to for further deliberation on the precautions to be taken.

1 Planning

1.1 The Drilling Department will have the Directional Drilling Contractor prepare a large scale surface hole plot with all nearby existing wells showing the plan view trace with true vertical depth marked at the magnetic multishot survey points.

1.2 The large scale plot will account for survey errors, film reading inaccuracies, etc. by plotting

survey points as ellipses of uncertainty so that each existing well will appear as a cone below 500 meter as uncertainty increases with depth. The cone of each well will be defined as a Danger Zone. The minimum safe distance above 500 meters is set at 10 meters.

1.3 The Drilling Department will prepare a separate program that will contain a discussion and plan

is to how close the planned well will come to each well that is crossed or approached on the large scale plan, and precautions to be taken to assure no well is hit. This plan must be approved and signed by the Drilling Manager.

1.4 In the event the planned well cannot be designed so that the existing wells will not give

magnetic interference (assume magnetic interference occurs within 6 feet), the drill pipe gyro survey instrument will be used to obtain directional survey.

1.5 In the event the planned well must enter into the Danger Zone of an existing well the planned

well must be jet drilled (down hole motor or rotary drilling is not permitted) past the existing well. If any indication of magnetic interference exists and conditions warrant, the rest of the surface hole will be drilled with a down hole motor so that the hard-banded drill pipe is not rotated against the existing casing string while drilling below the point in question.

1.6 Down hole tubing plugs or check valves should be set below the top packer in all tubing strings

and the casing and tubing pressures bled to zero in any existing well if the drilling well penetrates the Danger Zone below the surface casing or intermediate shoe. Details for the above should be included in the drilling program.

2 Operations

2.1 While drilling any portion of the hole in close proximity to the Danger Zone of existing wells, the Directional Driller will remain on the floor whether drilling with a down hole motor, jetting assembly or rotary assembly. He will monitor drilling parameters and pump pressures for any change that would indicate encountering cement or metal from an existing well.

2.2 The Directional Driller will calculate, plot and project the drilling well as surveys are taken and

keep the PCSB Drilling Supervisor informed of how far the drilling well is from the Danger Zone of any existing well.



2.3 Anytime the drilling well approaches an existing well within the attached Danger Zone, pressurization of annuli of existing well may be considered upon discussion with the PCSBHeadquarters.

2.4 In the event the drilling well enters into the Danger Zone of an existing well, only jet drilling (no

motor, no rotary) will be used until the Danger Zone has been passed. (If it is not possible to continue with jet drilling, the well will be plugged.)

2.5 If it becomes evident that a collision is imminent, immediately stop drilling, pull back the kelly,

secure the well and advise the PCSB Headquarters whilst observing the wells concerned.



Appendix 4

The approved SISO shall be introduced and discussed at the respective installation site prior to

Simultaneous Operations implementation by the execution party.

Appendix 4.1 SISO FLOW CHART – Production and Drilling

Petroleum Engineering Division (PED) or appointed representatives to

initiate proposal with inputs from relevant parties:

- Define scope and activities

- Identify risks and exposures

- Assess risk by conducting either Qualitative risk assessment or

quantitative risk assessment and demonstrate risk level is ALARP

- Identify control and recovery measures

Prepared by Drilling and Operation Engineers

Reviewed by Drilling Supervisor (DS), Operation Engineer (FE) and

Offshore Installation Manager (OIM)

Endorsed by Drilling Department (DDR), Field Manager (FM),

Regional HSE Department (xSE)

Approved by Regional Production Manager (xPD)

Presented by OE and DS to all crew onboard



Appendix 4.2 SISO FLOW CHART – Production and Construction

Maintenance Engineering Department (XME) or appointed

representatives to initiate proposal with inputs from relevant

parties:



-Assess risk by conducting either Qualitative Risk Assessment or Quantitative Risk Assessment and demonstrate risk level is ALARP


Prepared by Construction Engineer

Reviewed by Regional Maintenance Engineering Department –

Construction Section (xME 1), Operation Engineer (FE) and

Offshore Installation Manager (OIM) / Terminal Superintendent (TS)

Endorsed by Regional Maintenance Engineering Department (xME), Field

Manager (FM), Regional HSE Department (xSE)


Presented by OE and CE to all crew onboard



Appendix 4.3 SISO FLOW CHART – Production and Commissioning & Hook Up

Commissioning

Maintenance Engineering Department (XME) / Project

Management Team (PMT) or appointed representatives to

initiate proposal with inputs from relevant parties:



-Assess risk by conducting either Qualitative Risk Assessment

or Quantitative Risk Assessment and demonstrate risk level is

ALARP


Prepared by Engineer In Charge or by Hook Up and

Commissioning Engineer

Endorsed by Field Manager (FM), Regional HSE Department

(xSE)


Presented by OE and HUC to all crew onboard

Reviewed by Regional Maintenance

Engineering Department (xME),

Operation Engineer (FE), Offshore

Installation Manager (OIM) / Terminal

Superintendent (TS)

Reviewed by Operation Engineer

(FE), Hook-Up & Commissioning

(HUC) Manager and Offshore

Installation Manager (OIM) /

Terminal Superintendent (TS)



Appendix 4.4 SISO FLOW CHART–Production and Maintenance

Maintenance Engineering Department (XME) / Project

Management Team (PMT) or appointed representatives to

initiate proposal with inputs from relevant parties



- Assess risk by conducting either Qualitative Risk Assessment


ALARP


Prepared by Maintenance Engineer

Reviewed by Regional Maintenance Engineering Department (xME)

and Operation Engineer (FE)

Endorsed by Regional Maintenance Engineering Department

(xME), Field Manager (FM), Regional HSE Department (xSE)


Presented by ME to all crew onboard


PETRONAS CARIGALI SDN BHD Appendix 4

Page A4-5

Appendix 4.5 SISO FLOW CHART – Production and Wireline / Coil Tubing Unit

(CTU)

Petroleum Engineering Division (PED) or appointed

representatives to initiate proposal with inputs from relevant

parties:



- Assess risk by conducting either Qualitative Risk Assessment


ALARP


Prepared by Well Intervention Engineer

Reviewed by Well Intervention TP and Offshore/Onshore

Installation Manager (OIM)

Endorsed by Regional Well Intervention Manager (xWI), Field

Manager (FM) and Regional HSE Department (xSE)


Presented by Wireline Engineer to all crew onboard



Appendix 5

Matrix of Permitted Operations (MOPO)

The SISO document shall capture the MOPO for the safe execution of the Simultaneous Operations activity.

Table A4-1 Typical MOPO



Table A4-2 Typical SIMOPS Decision Matrix

simultaneous operations guidelines - petronas... · applicable throughout petronas carigali global...

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