Simultaneous Operations
This document is intended as a general guideline to assist Contractors with understanding and applying Safe Work Practice expectations.
Posted March 29, 2012 © 2012 Chevron U.S.A. Inc.
Simultaneous Operations
Table of Contents
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Guidelines ........................................................................................................................... 3 Bureau Of Ocean Energy Management, Regulation and Enforcement (BOEMRE)(formerly MMS) - Waiver Requests ............................................. 3
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Requirements ..................................................................................................................... 3 Terms and Definitions ....................................................................................................... 4
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Roles, Responsibilities, and Training Requirements...................................................... 5 4.1 Initial Training ........................................................................................................... 8
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Standard Instructions ....................................................................................................... 8 5.1 Production Operations ............................................................................................... 8 5.2 Rig Operations or Rig Moves .................................................................................... 9 5.3 Construction Activities, Including Electrical and Instrumentation (I&E) ................. 9 5.4 Anchoring of Vessels............................................................................................... 10 5.5 Mobilization and Demobilization of Equipment ..................................................... 10 5.6 Derrick Barge .......................................................................................................... 11 5.7 Seismic or Geotechnical Operations........................................................................ 11 5.8 Heavy Lifts by Stationary Cranes ............................................................................ 11 5.9 Aircraft Landing and Takeoff .................................................................................. 12 5.10 Diving Work ............................................................................................................ 12 5.11 Emergency and/or Spill Response ........................................................................... 13
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Records ............................................................................................................................. 13 6.1 Required Records .................................................................................................... 13 6.2 Retention Requirements .......................................................................................... 13
Simultaneous Operations
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Guidelines Ensure that simultaneous operations are performed in a safe and controlled manner. For the purpose of SimOps Activities, close proximity is defined as near enough to have an impact with another covered activity or will have interaction with another covered activity. Production Operations
Rig Operations or Rig Moves
Construction Operations, including Electrical and Instrumentation (I&E)
Use of Shared Road Networks
Anchoring of Vessels
Mobilization and Demobilization of Equipment
Derrick Barge Operations
Seismic or Geotechnical Operations
Heavy Lifts
Aircraft Landing/Takeoff
Diving Operations
Emergency and/or Spill Response
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Production activities concurrent with Construction activities only requires a Permit to Work, but depending on specific hazards and complexity of the project as identified by the Field Management Team, SimOps procedures may be required. Refer to the PTW/SimOps Decision Matrix to help determine the need for utilizing Permit to Work only or Permit to Work and SimOps. All Simultaneous Operations Plans will be used in conjunction with the Permit to Work Process.
Bureau Of Ocean Energy Management, Regulation and Enforcement (BOEMRE)(formerly MMS) - Waiver Requests A Simultaneous Operations Plan does NOT automatically grant us permission to depart from any regulations. If departures from regulations are necessary in order to perform the Simultaneous Operations, then such departures (also commonly referred to as waivers), must be requested from the appropriate agency.
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Requirements 1. Communication shall be established at the outset of simultaneous operations (SimOps) and maintained daily through both normal and abnormal conditions and documented on the Daily Simultaneous Operations Log. 2. SimOps should be discussed daily at shift/tourly meetings between all parties. 3. A Simultaneous Operations Plan must be used to create a written plan that:
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Designates the responsible parties for the various operations being performed
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Establishes emergency response awareness and contacts
Simultaneous Operations
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Identifies hazards and appropriate mitigations (precautions and actions)
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Clarifies communication between the various operations
4. A Simultaneous Operations Log must be used during simultaneous operations, and is to be completed daily by the SimOps Controller prior to commencement of simultaneous operations. 5. A Simultaneous Operations Plan Checklist must be used for compliance with the Simultaneous Operations Plan. The checklist is provided to use as a tool to ensure ongoing compliance with the SimOps plan. It is to be completed by the SimOps Controller. SimOps Plan Form – Prior to start of SimOps activities • Responsibility of the project initiator: Operations Engineer, Drilling Engineer, Facilities Engineer, Operations Supervisor • The Plan is a bridging document to help create a tangible plan including completion of a Risk Assessment. • Designates the responsible parties for the various operations being performed • Establishes emergency response awareness and contacts • Identifies hazards and appropriate mitigations (precautions and actions) • Clarifies communication between the various operations SimOps Plan Checklist – Prior to start-up and weekly thereafter • Responsibility of SimOps Controller: Drill Site Manager, Well Site Manager, Operations Supervisor • Must be used to ensure compliance with the Simultaneous Operations Plan • Completed by the SimOps Controller and members of the Field Management Team (FMT) SimOps Meetings – Daily/Tourly or as needed • Responsibility of SimOps Controller Daily SimOps Log – Daily • Responsibility of SimOps Controller • Used to document the discussion of projected activities of the day • Used during all Simultaneous Operations and is to be completed daily by the SimOps Controller
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Terms and Definitions The following terms and definitions apply to the Simultaneous Operations Safe Work Practices guidelines. Classified Hazardous Area – Any area classified as a hazardous zone area (Zone 0, 1 or 2, or Class I, Division 1 or 2) in accordance with API RP 505/API RP 500 or other equivalent local standards. Company Representative – A Company employee or designee who is responsible for liaising with and managing the contractor to ensure that the contractor performs the work safely in accordance with applicable Safe Work Practice standards. SimOps Controller – A Company employee or designee who is responsible for coordinating the Simultaneous Operations activities at a facility.
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Simultaneous Operations
The OS, OIM, DSM, WSM, or the Designee will act as the SimOps Controller and is responsible for coordinating Simultaneous Operations activities at a facility. SimOps Representative- A Company employee or designee who is responsible for coordinating one of the contributing Simultaneous Operations with the SimOps Controller. The Person Leading Work (PLW) will act as the SimOps Representative and is responsible for coordinating one of the contributing Simultaneous Operations with the SimOps Controller.
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Roles, Responsibilities, and Training Requirements Roles must be clearly defined, and personnel must meet the training and competency requirements of this guideline prior to starting work. A single individual may fulfill more than one role as long as he or she meets the competency requirements, and is able to fully meet multiple responsibilities. The following roles and responsibilities are specific to simultaneous operations. SimOps Controller Minimum Knowledge Requirement • • • • • • • • • • •
Ability to understand and control simultaneous operations The requirements of the relevant SWP Standards The permit process Hazard Identification & Evaluation Operations contributing to SimOps in their area of responsibility Hazards that may be encountered during operations in their area of responsibility Emergency Plan Daily Simultaneous Operations Log SimOps Plan Form and SimOps Checklist How to sound an alarm in the event of an emergency Can state their authority to stop work
SimOps Representative Minimum Knowledge Requirement • • • • • • • • •
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The requirements of the relevant SWP Standards The permit process Hazard Identification & Evaluation Hazards that may be encountered during operation in their area of responsibility The impact their activity could potentially have on other operations Emergency Plan SimOps Plan Form and SimOps Checklist How to sound an alarm in the event of an emergency Can state their authority to stop work
Simultaneous Operations
SimOps Controller (formerly Person-In-Charge (PIC))
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The SimOps Controller is the liaison between drilling & completion operations, construction, production operations, or other personnel, and coordinates their daily operations. The SimOps Controller shall communicate with SimOps Representatives (for each SimOps activity i.e., drilling, production, construction, etc.) the expected activities for the day at the commencement of each tour and as conditions require. Any anticipated conflicts or hazards due to the simultaneous operations should be resolved. Precautionary measures that will be taken during simultaneous operations shall be reviewed at that time.
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The SimOps Controller is in charge of all simultaneous operations procedures and is the:
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DSM/WSM on all drilling & completion operations
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Production Representative on all non- drilling & completion operations
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Management may designate a separate SimOps Controller that does not have drilling & completion or production responsibilities when the critical nature of the situation warrants
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The SimOps Controller is the simultaneous operations equipment and procedures reviewer. Prior to commencement of simultaneous operations, it shall be the responsibility of the SimOps Controller to inspect the drilling and completion worksite, construction, producing, and other equipment for compliance with these guidelines. It may be necessary to request assistance in the initial review from the Petroleum Engineering and Facility Engineering staff.
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The SimOps Controller should perform a review weekly using the SimOps Plan Checklist to ensure that all equipment is performing properly and procedures are being adhered too.
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The SimOps Controller shall document and be responsible for completion of orientation and drills concerning:
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Simultaneous operations procedures
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Emergency procedures
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Firefighting equipment operations and location
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ESD equipment operation and location
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Any person arriving on a structure shall be directed immediately to the SimOps Controller and then to the SimOps Representative of their particular operation (example: Drilling, Construction, or Production Representative) and shall state their business or purpose. They must be made aware of any non-routine or unusual operations in progress, or anticipated, and alerted to conduct their business accordingly. All visitors shall be logged in and instructed on precautions to be observed and safety procedures, such as fire and abandon platform emergency procedures to be followed.
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The SimOps Controller shall issue daily Hot Work Permits for all specific areas previously approved by the Operations Supervisor or, if designated by the Operations Supervisor (OS), the Field Coordinator.
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The SimOps Controller shall verify inspection and gas monitoring of all undesignated welding areas prior to commencing any hot work in accordance with the BOEMRE approved welding plan. The SimOps Controller shall verify continuous monitoring performed during hot work; and no less than 30 minutes after hot work is completed, a follow-up inspection shall be performed to ascertain if the area is secure.
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The SimOps Controller shall be notified and the area shall be monitored with a gas detector prior to starting and while operating engines with starters and alternators which are not suitable for hazardous locations. When starting these engines, they should have the same precautions as a welding operation.
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The SimOps Controller shall verify that certifications for all crane operators, riggers and welders, as well as the contractor's crane records, sling certifications, and inspections are in proper order prior to simultaneous operations.
Simultaneous Operations
Drill Site Manager (DSM) & Well Site Manager (WSM) •
The DSM/WSM is the SimOps Controller of the drilling & completion operations on location.
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The DSM/WSM is the SimOps Controller of all simultaneous operations and emergency situations while drilling & completion activities are present.
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The DSM/WSM shall initiate appropriate drilling rig shutdowns and/or production shutdowns based on company operating procedures.
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The DSM/WSM shall meet with the other SimOps Representatives to keep advised on both routine operations and non-routine operations as encountered. Planned meetings should be held daily at the beginning of each tour. The results of subject meetings shall be noted on the Daily SimOps Log.
Production Representative During drilling & completion Operations •
The Production Representative is the SimOps Representative of the production operations on the structure.
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The Production SimOps Representative shall ensure that all fire systems are inspected or tested as appropriate on a weekly basis and maintain them in a ready condition.
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The Production SimOps Representative shall initiate production shut-ins and depressurize equipment based on normal operating procedures.
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The Production SimOps Representative shall meet with the other SimOps Representatives & the SimOps Controller to keep advised of all routine operations and non-routine operations as encountered. Planned meetings should be held daily at the beginning of each tour. The results of subject meetings shall be noted on the Daily SimOps Log
During Non- drilling & completion Operations •
The Production Representative shall normally be the SimOps Controller of simultaneous operations and emergency situations when no drilling & completion activities are present.
All Other Company, Construction, and Contractor Supervisors
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Each SimOps Representative shall be aware of all simultaneous operations activities.
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Each SimOps Representative shall meet daily or by tour with the SimOps Controller to discuss job activities for the day/shift.
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The SimOps Controller is responsible for maintaining the Daily Simultaneous Operations log.
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The SimOps Controller is responsible for conducting a weekly review of the Daily Simultaneous Operations Log.
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Each SimOps Representative shall know the location and operating procedures of all ESD stations and emergency equipment.
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Each SimOps Representative shall ensure that all personnel know emergency drill procedures and participate in all emergency drills.
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Each SimOps Representative shall immediately notify the SimOps Controller of any unsafe work or platform conditions.
Simultaneous Operations
4.1 Initial Training Personnel must meet the competency requirements of this standardized safe work practice prior to starting work. Refresher training must be provided as follows:
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As required by applicable regulations or company policy
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As needed when identified by verification, inspections, incidents, or audits
Standard Instructions Simultaneous Operations (SimOps) is defined as, but not limited to, performing two or more of the following operations concurrently in close proximity: Production Operations
Rig Operations or Rig Moves
Anchoring of Vessels
Mobilization and Demobilization of Equipment
Derrick Barge Operations
Seismic or Geotechnical Operations
Heavy Lifts
Aircraft Landing/Takeoff
Diving Operations
Emergency and/or Spill Response
This process does not preclude establishing more restrictive limitations that may be warranted by particular circumstances or conditions. The SimOps Plan Form and the SimOps Checklist must be used to ensure ongoing compliance with the SimOps process. The key element during SimOps is communication. It is imperative that clear and continuous communications be maintained between all personnel performing work. This communication shall be established at the beginning of SimOps, maintained daily through both normal and abnormal conditions, and documented on the daily SimOps Log. SimOps will be discussed daily at shift/hourly meetings. The SimOps Controller working with the SimOps Representatives (for each SimOps activity, i.e., drilling, production, construction, etc.) shall contribute to the SimOps plan. The SimOps Controller will have authority if necessary to determine which operation or phase of work has priority at a given time. Before the commencement of Simultaneous Operations, representatives from all departments involved must meet to discuss the details of the work to be performed. 5.1 Production Operations Production Operations is a broad category of work that includes activities such as production wireline operations, well workovers, blasting, and painting. The Production SimOps Representative will discuss planned activities and potential hazards of production activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The Production SimOps Representative is responsible for updating and communicating the production work plan to accommodate SimOps where required.
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Simultaneous Operations
Production Operations may also include, but not limited to: •
Any component of a production system that is pressurized and/or has the ability to become pressurized during the anticipated duration of the scheduled work.
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This includes, but not limited to: Vessels, Headers, Process Piping, and Pipelines…..etc. Any anticipated operator activities on the structure during the anticipated duration of the scheduled work. This includes, but not limited to: • Manned & Un-Manned Structures • Well testing • Compliance testing • Anything that requires vessel access to the structure • Any wireline activities • Any sandblasting & painting activities
Production activities concurrent with Construction activities only requires a Permit to Work, but depending on specific hazards and complexity of the project as identified by the Field Management Team, SimOps procedures may be required. Particular attention to significant risk assessment items and additional risk exposure under Precautions and Action Guidelines for Production Operations is required. 5.2 Rig Operations or Rig Moves The Rig SimOps Representative will discuss planned activities and potential hazards of rig activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The Rig SimOps Representative is responsible for updating and communicating the rig work plan to accommodate SimOps where required. Drilling and Completion Rigs, MODU or a lift or jack-up boats must operate in compliance with the U.S. Department of the Interior, Bureau of Ocean Energy Management, Regulation and Enforcement Notice to Lessees (NTL) 2008-G05 & 2009-G25 is required. Particular attention to significant risk assessment items and additional risk exposure under Precautions and Action Guidelines for Drilling and Completions Operations/Rig Moves (Drilling; Workover; Snubbing; Coiled Tubing; Electric Line) is required. 5.3 Construction Activities, Including Electrical and Instrumentation (I&E) Construction activities, including Electrical and Instrumentation (I&E), is a broad category of work that covers a wide range of activities. The Construction SimOps Representative will discuss planned activities and potential hazards of construction activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The Construction SimOps Representative is responsible for updating and communicating the construction work plan to accommodate SimOps where required. • •
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Production activities concurrent with Construction activities only requires a Permit to Work, but depending on specific hazards and complexity of the project as identified by the Field Management Team, SimOps procedures may be required. Refer to the PTW SimOps Decision Matrix to help determine the need for utilizing Permit to Work only or Permit to Work and SimOps.
Simultaneous Operations
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All Simultaneous Operations Plans will be used in conjunction with the Permit to Work Process.
Particular attention to significant risk assessment items and additional risk exposure under Precautions and Action Guidelines for Construction Operations is required. 5.4 Anchoring of Vessels Communication links shall be established between the vessel and production operations prior to all anchoring operations. Every effort shall be maintained during anchoring operations to avoid endangering pipelines and submarine cables. If a pipeline’s location is in doubt, the lines in question should be bled down prior to anchoring operations. The SimOps Representative will discuss planned activities and potential hazards of anchoring activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The SimOps Representative is responsible for updating and communicating the work plan to accommodate SimOps where required. Prior to all anchor handling operations a pre-move meeting addressing, at a minimum, stop work authority, deteriorating weather, roles and responsibilities, risk assessment, crew handover requirements, notification procedures for mechanical malfunction/injury/spill, and stability, shall be held onshore and offshore. The 500 / 1,000 foot rule will apply. The 500 / 1,000 foot rule is defined as follows: Anchors are not dropped closer than 500 feet from a pipeline. If crossing a pipeline, the anchor should not be dropped closer than 1,000 feet of the pipeline in the direction of the anchor pull. Whenever anchors are required to be placed closer to the pipelines than the recommended 500 / 1,000 foot rule, then discussions with the vessel operator and the reasons for a variation from the 500 / 1,000 foot rule are required. The surveyor will request an all stop until all parties agree to the process for setting anchors. The proposed change in anchor layout shall be submitted to the Project Manager. For pipe lay barges, derrick barges and dive support vessels; the contractor’s anchor handling procedures will be submitted to the Project Manager for the project for review and concurrence. Particular attention to significant risk assessment items and additional risk exposure under Precautions and Action Guidelines for Anchoring of Vessels is required. 5.5 Mobilization and Demobilization of Equipment The SimOps Representative will discuss planned activities and potential hazards of mobilization/demobilization activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The SimOps Representative is responsible for updating and communicating the work plan to accommodate SimOps where required. For Rig Moves/Rig Skids/Rigging Up & Down, refer to Section 5.2 in addition to Precautions and Action Guidelines for Drilling and Completion Operations/Rig Moves (Drilling; Workover; Snubbing; Coiled Tubing; Electric Line), For lifts and moving heavy equipment in the area of producing wells or production equipment, refer to Section 5.1, as well as the Precautions and Action Guidelines for Production Operations. For mobilization and demobilization of equipment during construction activities, refer to Section 5.3 and the Precautions and Action Guidelines for Construction Operations.
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Simultaneous Operations
The Lifting and Rigging Guideline should be used for further guidance. Also reference the MSRE Cargo Handling Process. The loading, stowing, and discharging of cargo to and from a vessel are activities that pose significant risk of injury. The vessel Master has ultimate responsibility for acceptance of cargo to and from the vessel and the stowage and separation of cargo on and below deck. Heavy lifts will require a lifting plan to be developed prior to commencing the operation. 5.6 Derrick Barge For SimOps Derrick Barge activities, the SimOps Checklist and SimOps Plan Form must be used for each project or scope of work. These documents are intended to be tools that improve job planning, and minimize exposure to environmental and safety hazards. Lines of communication shall be established between the derrick barge, crane operator, offshore operations, inland operations, SimOps Representatives, and the SimOps Controller before setting anchors in the field. The Derrick Barge SimOps Representative will discuss potential hazards of the planned activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The SimOps Representative is responsible for updating and communicating the work plan to accommodate SimOps where required. Particular attention to significant risk assessment items and additional risk exposure under Precautions and Action Guidelines for Derrick Barge is required. For additional guidance on anchoring procedures, reference Section 5.5 and MSRE Anchoring Process. 5.7 Seismic or Geotechnical Operations The SimOps Representative will discuss planned activities and potential hazards of seismic or geotechnical activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The SimOps Representative is responsible for updating and communicating the work plan to accommodate SimOps where required. Seismic Operations occurring in close proximity of Drilling and Completion Operations, specifically during perforating operations, will adhere to the radio silence procedure. All devices that transmit/receive a telecommunication signal/frequency, (i.e., two-way, microwave & SCADA radios, cell or cordless phones, satellite devices, Sky Connect GPS, pipeline sales radio transmitters, etc.), will be shut off while these tools are armed and until they are 250’ below the mud line. Seismic activity adjacent to or concurrent with diving activity should not be performed within a minimum of a one mile radius. As a precaution, Seismic operations should include communication over the VHF to alert other activities. 5.8 Heavy Lifts by Stationary Cranes A heavy lift is defined as a non-routine lift (drilling, workover, construction, wireline, etc.) which is equal to or greater than 75 percent of the rated capacity of the crane, at either a dynamic or static condition. Use the load chart for rated capacities. Heavy lift crane operations shall be conducted in accordance with the Lifting and Rigging Guideline. At a minimum, three actions are required: a lift team is established, a pre-lift meeting is conducted, and a written critical lift JSA is prepared. The Heavy Lift
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Simultaneous Operations
SimOps Representative will discuss potential hazards of the planned activities with the SimOps Controller. Any identified hazards and steps to mitigate hazards will be documented in the SimOps Plan Form. The SimOps Representative is responsible for updating and communicating the work plan to accommodate SimOps where required. Particular attention to significant risk assessment items and additional risk exposure under Precautions and Action Guidelines for Heavy Lifts by Stationary Cranes over Pressurized Equipment is required. The Lifting and Rigging Guideline should also be used for additional guidance. 5.9 Aircraft Landing and Takeoff Communication links shall be established between the aircraft and the landing field or heliport prior to all aircraft landings and takeoffs. Trip planning in accordance with the ASRE Process must be followed. A Permit to Work and the SimOps Form are not required for aircraft operations unless instructed by the SimOps Controller Aviation Safety process. If the SimOps Controller designates aircraft operations as a SimOps activity, then a SimOps Representative shall be assigned to discuss potential hazards of the planned activities with the SimOps Controller. The SimOps Representative is responsible for updating and communicating the work plan to accommodate SimOps where required. •
Helicopter operations must be advised prior to abrasive blasting operations in process to protect helicopter engines from ingestion of abrasive particles that could damage them. Reference Precautions and Action Guidelines for Production Operations.
Helicopters are not allowed to land during radio silence/perforating operations. Reference Precautions and Action Guidelines for Drilling and Completion Operations/Rig Moves. For Ship/Drilling Rig/Work Barge Operations, a “green deck” clearance is required prior to landing. Reference ASRE Process, Aircraft Operations Manual for additional guidance. Where cranes are positioned in the proximity of helidecks or approach/take-off zones, they will not be operated while the helicopter is landing, taking off, or running on the heliport. If a crane is in use and cannot release its load, the crane's boom will be positioned away from the heliport and secured to prevent swinging. If feasible, the crane should be shut down. Unless the qualified crane operator is in direct voice communication with the helicopter pilot, the qualified crane operator will not be at the control station during helicopter landings, take-offs, or while a helicopter is running on the heliport. Any crane not in use that could affect helicopter operations will have its boom cradled. Reference the Lifting and Rigging Procedure for additional guidance. 5.10 Diving Work For all SimOps diving activities, the SimOps Checklist and SimOps Plan Form must be used for each project or scope of work. These documents are intended to be tools that improve job planning and minimize exposure to environmental and safety hazards. A diving project requires a pre-job safety and planning meeting with parties involved to ensure proper communication on the project. The SimOps Controller ensures the coordination of the project with the SimOps Representatives. The meeting should be held at the jobsite prior to diving activities or any substantial change in work scope.
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Simultaneous Operations
Particular attention to significant risk assessment items and additional risk exposure under Precautions and Action Guidelines for Diving Work is required. For additional guidance, review the MSRE Vessel & Installation Communication process. 5.11 Emergency and/or Spill Response For emergency response activities involving SimOps, the Emergency Response process must be followed and any permits required by that process must be issued. For spill responses involving SimOps (defined as spill response that occurs after the initial emergency response is over), a Permit to Work, appropriate work permits (Hot Work, Confined Space, etc.), SimOps Checklist and SimOps Plan Form must be used. These documents are intended to be tools that improve job planning and minimize exposure to environmental and safety hazards. The Spill Response SimOps Representative will discuss potential hazards of the planned activities with the SimOps Controller. As required by the Emergency Management Process, the National Interagency Incident Management System (NIIMS), Incident Command System (ICS) is the tool utilized for emergencies and spill response. The ICS is the hazard control mechanism and communication tool for concurrent activities. This protocol is addressed in the numerous response plans approved by numerous agencies. When the NIIMS ICS is not utilized (i.e., upon stand down), then the SimOps process will be utilized as necessary.
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Records
6.1 Required Records Copies of permits and associated documentation shall be maintained in accordance with the Permit to Work guideline. 6.2 Retention Requirements Documentation shall be retained as required by local regulation, company policy or for a minimum of six months, whichever is greater.
© 2012 Chevron U.S.A. Inc.
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