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Petroleum Development Oman L.L.C. Document title: H 2 S and SO 2 Management Operations Document ID SP-1190-4 Document Type Specification Security Unrestricted Discipline Technical Safety Engineering Owner MSE/4 – CFDH Technical Safety Engineering Issue Date February 2019 Version 5.0
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Page 1: Petroleum Development Oman L.L.C.

Petroleum Development Oman L.L.C.

Document title: H2S and SO2 Management

Operations

Document ID

SP-1190-4

Document Type

Specification

Security

Unrestricted

Discipline

Technical Safety Engineering

Owner

MSE/4 – CFDH Technical Safety Engineering

Issue Date

February 2019

Version

5.0

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i Document Authorisation

Document Authorisation

Document Authority

Lucien Van Ham (MSE4)

Document Custodian

Lesley Tallentire (MSE47)

Document Controller

Lesley Tallentire (MSE47)

Van Ham, Lucien MSE4

Date : 17-02-2019 8:30 AM

Tallentire, Lesley MSE47

Date : 17-02-2019 8:29 AM

Tallentire, Lesley MSE47

Date : 12-02-2019 10:00 AM

ii Revision History

The following is a brief summary of the 3 most recent revisions to this document.

Version No. Date Author Scope / Remarks

5.0 Jan-19 Lesley Tallentire, MSE47

1190-4 Update to take account of change in Red Zone Entry requirements and to add an H2S L2 Operational Audit checklist. Isolation and Purging addressed in other PRs, so sections removed.

4.0 Aug-15 Lesley Tallentire, MSE47

See 1190-1

3.0 Sep-11 Ian Jewitt, MSE4 See 1190-1

iii CMF Impacted documents

The related CMF Documents can be retrieved from the Corporate Business Control Documentation Register CMF.

Related CMF Document Links

Code CMF Document

SP-1125 Isolation of Process Equipment Specification

SP-1219 Well Engineering Hydrogen Sulphide Specification

SP-1234 HSE Specification – Personal Protective Equipment

PR-1076 Isolation of Process Equipment

PR-1078 Hydrogen Sulphide Management Procedure

PR-1080 Well Testing, Scheduling, Sampling and Validation

PR-1172 Permit to Work Procedure

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iv SP-1190 Standard Development

This document SP-1190-4, fits into the structure as noted below:

1190- 1 The Basics, Classification and Sour Contracts 1190-2 Well Engineering 1190-3 Engineering Design 1190-4 Operations 1190-5 H2S RPE and Training

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TABLE OF CONTENTS

i Document Authorisation ......................................................................................................................... 3

ii Revision History ..................................................................................................................................... 3

iii CMF Impacted documents ..................................................................................................................... 3

iv SP-1190 Standard Development ........................................................................................................... 4

1 Introduction ............................................................................................................................................ 6

1.1 Purpose ............................................................................................................................................ 6

1.2 General Definitions ........................................................................................................................... 6

Glossary ......................................................................................................................... 6

Abbreviations .................................................................................................................. 7

2 H2S Facilities Classification .................................................................................................................... 8

2.1 Classification Definitions – Sweet, Sour, Critical Sour ..................................................................... 8

2.2 Mandatory Minimum Entry Requirements per Facility Classification ............................................... 9

3 Facility Zoning ...................................................................................................................................... 10

3.1 Red and Yellow Zoning .................................................................................................................. 10

Red Zone Working Requirements ................................................................................ 10

Yellow Zone Working Requirements ............................................................................ 13

3.2 Emergency Planning Zone (EPZ) Classification ............................................................................ 15

EPZ Working Requirements ......................................................................................... 15

3.3 SIMOPS Zoning (Simultaneous Operations) ................................................................................. 17

SIMOPS Zones Working Requirements....................................................................... 17

3.4 Well Test Flaring Zoning ................................................................................................................ 18

Well Test Flaring Zoning Working Requirements......................................................... 18

4 Working in H2S Facilities ...................................................................................................................... 19

4.1 Permit to Work ............................................................................................................................... 19

4.2 Job Planning, Hazard Identification and Assessment .................................................................... 19

4.3 Numbers of Personnel on Site ....................................................................................................... 20

4.4 Activities requiring Breathing Apparatus (BA) ................................................................................ 20

4.5 Gas Detection Methods .................................................................................................................. 21

4.6 Departure from Site ........................................................................................................................ 21

5 H2S Alarms and Facility Emergency Response ................................................................................... 22

5.1 Rescue ........................................................................................................................................... 22

5.2 Emergency Procedures and Drills .................................................................................................. 22

6 Appendix 1 - Operational H2S Management for Sour and Critical Sour Facilities ......................................... 23

6.1 Critical Sour Operational L2 Audit Checklist .................................................................................. 24

6.2 Sour Operational L2 Audit Checklist .............................................................................................. 29

6.3 Audit Report ................................................................................................................................... 33

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1 Introduction

1.1 Purpose

This document, SP-1190-4, is aimed at the management of PDO H2S facilities in the operations phase. It provides personnel with the knowledge to be aware of the hazards associated with H2S & SO2. PDO facilities process fluids which contain varying levels of H2S. This specification details the steps that they are required to take to assess and manage the associated risk. It details how they can protect themselves and others within production operations in order to reduce risks to be As Low As Reasonably Practicable (ALARP).

1.2 General Definitions

The lower-case word shall indicates a mandatory requirement.

The word should indicates a recommendation.

Glossary

Key terminology is identified within SP-1190-1 The Basics, Classification & Sour Contracts and also in Table 1-1.

Table 1-1 Key Terminology

Term Explanation

Sweet Facility The classification given to a facility or wellhead containing fluids with Hydrogen Sulphide concentrations below 100ppm in the gas phase and less than 20mg/l in the non-gaseous phase.

Sour Facility The classification given to a facility or wellhead containing fluids with concentrations of Hydrogen Sulphide above 100ppm in the gas stream and more than 20mg/l in the non-gaseous phase, but less than 5 bar(a) H2S partial pressure.

Critical Sour Facility

A facility which operates with partial pressures of H2S approaching or above 5 bar(a). The pressure used for this classification is the maximum allowable operating pressure.

The definition is purposefully worded, as approaching 5 bar(a), such that facilities which process 4.9bar(a), and those which process 5 bar(a) are not afforded different risk reduction measures without due consideration to the whole risk picture.

Where facilities operate with partial pressures of H2S above 4 bar(a), but under 5 bar(a), an assessment of the conditions shall be made to determine whether the additional controls in place for the defined Critical Sour Facilities, are required in this case. The assessment shall be recorded and form part of the facility ALARP justification, and shall be included in the facility HSE Case.

Critical Sour classification is required to capture the operational and design requirements, which lead to a step change in the way that risks are managed, due to inherently high residual individual risk levels.

Emergency Planning Zone

An area around a Sour or Critical Sour facility or wellhead, where additional precautions, including a Emergency Response (Contingency) Plan are required. The Emergency Response Plan describes how personnel and other potentially affected parties would be notified and evacuated in case of a Loss of Primary Containment.

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Term Explanation

Red Zone An area, on a Critical Sour facility where enhanced procedures shall be adopted. Personnel shall don breathing apparatus when entering the Red Zone. The area is typically the physical extent of the process unit containing the hazard, and is identified with warning signs.

Yellow Zone An area on a Critical Sour or Sour facility where enhanced procedures shall be adopted. Personnel shall be equipped with supplied air personal escape sets and H2S monitors. Breathing apparatus is expected to be worn during any operation or maintenance activity where there is a real or perceived threat of a H2S release. The area is typically the physical extent of the process unit containing the hazard, but may extend to cover the area within the property limits of a facility.

SIMOPS Zones

A SIMOPS Zone is an area where 2 or more activities (e.g. production and drilling) are undertaken simultaneously, under different control systems in overlapping spheres of influence, or hazard zones.

Well Test Flaring Zoning

A Well Test Flaring Zone is an area around a well test flare / pit, where controls are put in place to limit potential exposure to SO2, or H2S in the event of flare out.

Occupied Building The term Occupied Building is in accordance with DEP 34.17.10.32-Gen.

Abbreviations

ALARP As Low As Reasonably Practicable

POB Personnel On Board (at site)

BA Breathing Air PPM Parts Per Million

CRO Control Room Operator PR Procedure

CP / CoP Code of Practice PTW Permit To Work

DEP Design and Engineering Practice

PVV Pressure Vacuum Valve

DTL Delivery Team Leader RPE Respiratory Protective Equipment

EPZ Emergency Planning Zone SCBA Self Contained Breathing Apparatus

F&G Fire & Gas SIMOPS SIMultaneous Operations H2S Hydrogen Sulphide SO2 Sulphur Dioxide

HSE Health Safety Environment SP Specification

JHSEP Job HSE Plan SPZ Special Precautions Zone H2S Hydrogen Sulphide TEZ Total Exclusion Zone

MOPO Manual Of Permitted Operations

TRIC Toolbox Risk Identification Card

MSE4 Technical Safety Department TWL Thermal Work Limit

PDO Petroleum Development Oman WTU Well Test Unit

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2 H2S Facilities Classification

Hydrocarbon facilities are given a classification based on H2S levels at that facility, this has an impact on many of the design decisions to be made, and also the operational controls required. In addition, specific areas within the facilities are zoned, to enable the risks to personnel to be further controlled.

To date, no PDO facilities have been classified based on SO2 levels.

2.1 Classification Definitions – Sweet, Sour, Critical Sour

Hydrocarbon Facilities within PDO are defined as:

Sweet

Sour

Critical Sour

Details of how this classification is established are held within SP-1190-1. Table 2-1 provides a summary for gas streams.

Table 2-1 Facility Classification for Gas Streams

Sweet

<100ppm H2S in gas phase

≥ 100ppm

Sour

<approaching 5 bar(a) H2S partial pressure

Critical Sour

Approaching & > 5 bar(a) H2S partial pressure

The facility is classified based on what is carried through its pipes and equipment, rather than what the pipes and equipment are made of.

The classification of a facility is based on the maximum level of controls which are required for a facility as a whole. There is an exception based on sufficient separation distances (see SP-1190-3).

If a facility is classified as SWEET, no further application of this standard is required. However, the classification exercise shall be formally recorded and levels of H2S shall be monitored, by site sampling.

PDO operates its facilities in line with the CP-122 Health, Safety and Environment Management System, and many supporting operational procedures. The requirements of this SP, in no way replace any of those requirements. This SP is supplementary to the existing controls in place. Operations staff at each facility shall understand the classification of their facility and the appropriate level of entry controls that apply:

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2.2 Mandatory Minimum Entry Requirements per Facility Classification

Table 2-2 summarises the minimum entry requirements for PDO facilities based on their classification. There are additional requirements for entry into zoned areas, which are detailed in the subsequent sections of this SP.

Standard PDO entry requirements are in place for all facilities and these are:

PTW, or

Access Authorisation Form or

Asset holders exemption.

Table 2-2 Facility Classification Operational Entry Requirements

Sour Critical Sour

Entry Standard + H2S Training Card As Sour + Buddy system + Site Induction

Visitor Entry

(Non H2S trained)

By exception from DTL# By exception from Operations Manager#

Equipment required Personal H2S Detector

+ Filter Hood

Personal H2S Detector

+ supplied air RPE

# Non H2S Trained entry to Sour Facilities is by exception and the following is required:

Access Authorisation Form,

Respiratory Protective Equipment demonstration & visitor practice before entry to site,

Accompanied onto facility at all times.

All supplied air escape sets and filter hoods shall be in compliance with the latest version of SP-1234 Personal Protective Equipment, and SP-1190 – 5, when it becomes effective.

It should be noted that any head scarves will need to be removed prior to donning Escape Sets or Filter Hoods.

Typically personal gas detectors shall be provided in accordance with SP-1234. However, in contradiction to SP-1234, which states alarm level for personal detectors will be at 5ppm and 10ppm, personal detectors shall display levels of H2S in the atmosphere between 0-100ppm, and shall alarm at 10ppm H2S.

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3 Facility Zoning

Facilities which are Classified as either Sour or Critical Sour are further zoned. The zoning of the facility drives which controls which need to be provided in addition to the standard PTW and classification controls, within these specific areas. Further details of how the zones are sized / chosen are provided in SP-1190-3.

3.1 Red and Yellow Zoning

Red Zones are established in specific areas within Critical Sour facilities where the concentrations and pressures of H2S in the process fluids requires additional precautions to be taken, such as wearing breathing air.

Yellow Zones are implemented in both Critical Sour and Sour facilities where a 22mm release from the process can result in a toxic atmosphere which has the potential to cause fatalities 2m away from the release point.

Red Zone Working Requirements

Each Critical Sour Facility shall limit the numbers of personnel in a Red Zone to 5, with one observer remaining outside the Red Zone at all times. In reality the number of persons in the Red Zone may be less due to the limitations of the supplied air systems.

This is in compliance with Buddy System, which is in force (PR-1081 – The Buddy System). Any personnel working under Breathing Air shall attend PDO Approved Self Contained Breathing Air (SCBA) Training. A medical test declaring the person physically fit for the use of a SCBA should be completed in advance to SCBA training.

The number of Red Zones entered within a facility at any particular time shall be based on the ability of the operations team to monitor the red zone activities and their ability to mount simultaneous rescue. Typically, in practice this will mean only 1 red zone is being entered at any one time.

The following requirements shall be in place for Red Zone entry

Check Fixed F&G Status - Prior to entry to a Red Zone the control room operator shall

review the status of the F&G system, to ensure that there is no indication of a gas

release.

Monitor Cameras - If cameras have been provided, then the control room operator will

monitor the Red Zone during the manned entry.

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3.1.1.1 Red Zone Entry and Exit and Working using Supplied Breathing Air

Typically, Red Zones are provided with either a fixed Air Cascade system, Air Supply Skids, or Air Supply Trolleys, which can supply multiple users for a defined period – typically a number of hours. However the work/rest cycle is dependent upon Thermal Work Limit, which is influenced by a number of factors, such as the Dry and Wet Bulb temperatures. Further details for calculating the TWL are available from SP-2222, owned by MCOH1. Table 3-1 provides the rule set for personnel wearing supplied breathing air equipment, such as entering the Red Zone. As noted below, the longest duration to work under SCBA, before taking rest is 30 minutes.

Table 3-1 Work / Rest Cycle for SCBA Trained Persons using Supplied Air Breathing Equipment Outside

INDEX TWL VALUE WORK LOAD CATEGORIES

WORK RULES

Thermal

Work

Limit

(TWL)

<129 W/m2

(or dry bulb > 44°C or wet bulb >

32°C)

All work load categories

Stop Work Zone

Strictly 15 minutes work and 60 minutes rest cycle

Emergency Work only.

Conduct risk assessment before emergency work. Medical monitoring in place

130 to 159 W/m2 Heavy work load

130 to 159 W/m2 Moderate work load

≥ 160 W/m2 Heavy work load

Restricted zone

30 minutes work,

60 minutes rest cycle

Workers self-pace and can withdraw from work whenever feeling unwell.

Full acclimatization and hydration regime

130 to 159 W/m2 Very light and light work load

≥ 160 W/m2 Very light and light work load

Normal zone

30 minutes work and 30 minutes rest cycle

Workers self-pace and can withdraw from work whenever feeling unwell.

Full acclimatization and hydration regime implemented

Where an air supply system does not exist, full Self Contained Breathing Apparatus (SCBA) (typically a 45-minute bottle) shall be used to enter the Red Zone. The activity duration shall take account of the above and in addition be limited, such that in the event of escape being required, sufficient air will remain in the SCBA bottle to allow the individual to return the farthest facility assembly / muster area. This shall be proven by site trials, rather than by the times noted on the bottle capacities. This will be facility specific and shall be recorded in the Emergency Response Plans, be available within the Control Room and noted in any PTW requiring Red Zone Entry.

Note: The SCBA provided shall be in line with the latest version of SP-1234, and SP-1190-5, which currently is the CamLock Quest, with cowl hood.

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Table 3-2 Enter / Exit the Red Zone using Supplied Air Breathing System

To Enter and Exit the Red Zone:

USING SUPPLIED BREATHING AIR SYSTEM

Connect to Air Supply System.

Check time with Buddy and agree return time.

Don Cowl Hood on ‘Working and Escape Set’ (CamLock Rig Walker) prior to entry to the Skid.

Check personal H2S detector.

All persons required to carry the escape cylinder, (part of rig walker) which will automatically supply the wearer in the event that the main air line is disconnected.

Continue to work under Breathing Air until their work is complete. (30 mins max)

Return to Breathing Air Supply Area.

Check personal H2S detector.

Remove hood, at Breathing Air Supply Area, disconnect and return to Control Room to Rest.

Note, the air supply system may be; Cascade Air, Air Supply Skids or Air Trolleys

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Table 3-3 Enter / Exit the Red Zone using Self Contained Breathing Apparatus

To Enter and Exit the Red Zone:

USING SELF CONTAINED BREATHING APPARATUS (SCBA)

CONFIRM MAXIMUM DURATION ALLOWED WITHIN THE RED ZONE

Turn on air supply and Don Cowl Hood on SCBA (CamLock Quest) prior to entry to the Skid.

Check personal H2S detector.

Check time with Buddy and agree return time.

Continue to work under Breathing Air until their work is complete or the agreed time.

Return to Buddy.

Check personal H2S detector.

Remove hood, turn off air supply and return to Control Room to Rest.

Return used SCBA for refilling.

The red zone exists when the hazard is present, once the hazard is removed, the red zone requirements shall be relaxed, e.g. during a shutdown when purged and isolated.

Yellow Zone Working Requirements

The number of personnel within Yellow Zones shall be kept to a minimum. It should be based on the ability of operations team to monitor and control the activities. This is to be assessed within the plant Emergency Response Plan or Contingency Plan and recorded in the HSE Case. The Buddy System shall be implemented (PR-1081 – The Buddy System).

All entry into the Yellow Zone is with the use of the supplied air cylinder sets, (typically CamLock Rig Walker, with cowl hoods) not filter type hoods. See SP-1190-5 for more details.

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Table 3-4 Enter / Exit the Yellow Zone

To Enter and Exit the Yellow Zone:

Check personal H2S detector

All persons to carry either:

a ‘Critical Sour Escape Set’

(Typically, this is a CamLock Escape Set- orange bag- with Cowl Hood), OR

a ‘Critical Sour Working and Escape Set’ (Typically, this is a CamLock Rig Walker with Cowl Hood),

With sufficient air capacity to return to the farthest facility assembly area.

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3.2 Emergency Planning Zone (EPZ) Classification

The Emergency Planning Zone is an area where given a worst case release, there may be levels of H2S present in the air of 100ppm, or greater. The EPZ is in place to inform persons in the area of the potential hazards, to recognise and minimise the consequences of an H2S event and to allow PDO to manage the risks to As Low As Reasonably Practicable (ALARP).

Within PDO, a number of facilities operate with high levels of Hydrogen Sulphide, such that they apply the Emergency Planning Zone (EPZ) concept. Signboards are provided to allow persons to be aware that they have entered the EPZ, see Figure 3-1. In addition the EPZ can be seen as an ‘Administrative Boundary Layer’ on PDO Earth.

EPZ Working Requirements

The following details the requirements for working in the EPZ.

All work conducted inside the Emergency Planning Zone shall be covered by a Permit to Work.

A Job HSE Plan (JHSEP) shall be completed which should consider the ‘worst case scenario’ of an H2S leak. The plan should consider the area that would be impacted and the nature of the work being undertaken.

All workers have received approved valid H2S training.

Each work party has a viable communication method.

All persons have an H2S detector.

All workers have a filter type escape hood (SP-1190-5).

An emergency response plan is in place and a vehicle shall be available within walking distance.

Works in proximity to ‘Process Area’, as noted in the PTW risk assessment, to be provided with H2S monitoring and / or trained rescue personnel and equipment.

Safety Awareness briefings for all staff at the start of each shift.

Filter escape hoods have been specified for use in the EPZ, rather than supplied air sets for a number of reasons:

The expected concentrations of H2S are lower, as the hazard source is likely to be more

remote than for the on plot areas. The Approved Filter Hoods are based on ability to filter out 4400ppm H2S, including users with facial hair.

The distance to evacuate may be greater than on-plot leading to longer duration evacuations.

Filter hoods can be used for a longer duration, as there is no supplied air bottle to run out. Typically escape breathing air sets last for 10-15 minutes. Escape hoods are rated via their standards for 40 minutess, but can be worn for longer durations, especially if the H2S levels are lower than the rated contaminant concentration levels.

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It should be noted that you may still be able to smell H2S, but keep the hood on until the personal detector indicates that the H2S levels are below 5ppm, or you are advised by the muster checker to remove.

The production team may include the requirement for a supplied air escape set, within the PTW; if the work within the EPZ is in close proximity of a ‘Process Area’.

Figure 3-1 EPZ Entry Board

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3.3 SIMOPS Zoning (Simultaneous Operations)

SIMOPS Zones are established at Sour or Critical Sour facilities based on the SIMOPS QRA models (SP-1190-3). These SIMOPS zones apply for both On plot and Off plot facilities and are established to control the risks associated with large construction crews / or diverse management systems. Inner and Outer SIMOPS Zones are defined, based on the facility risks.

If an EPZ is in place, the Outer Zone requirements are met by the provision of the EPZ. Inner Zone requirements shall be complied.

If no EPZ is in place, both the Inner and Outer Zone requirements shall be complied.

An asset specific Matrix of Permitted Operations (MOPO) is required for all Critical Sour plants, which will be held at the Control Room. The MOPOs provide guidance on which activities may and may not be carried out simultaneously, and those which may be carried out simultaneously if special conditions apply. All Simultaneous or concurrent activities shall be in compliance with the approved SIMOPS Plan and the existing Facility MOPOs. If necessary a step-out from the MOPO can be applied via the PTW system.

SIMOPS Zones Working Requirements

The basic requirements for working within a SIMOPS Zone are defined within the PDO PTW Procedure PR-1172.

Inner Zone Outer Zone

All workers have received approved valid H2S training

Supplied Air Respiratory (SP-1190-5)

equipment to be carried. (Camlock Escape

Set or CamLock Rig Walker, with cowl

hood)

All workers have received approved valid H2S training

Filter Escape Hood (SP-1190-5, Typically

NH-15)

Self-Evacuation to be demonstrated (drills) Self-Evacuation to be demonstrated (drills)

Agreement with site on rescue provision Provision of 2 rescue trained personnel at

designated SIMOPS assembly location.

Personnel working within a SIMOPS Zone shall comply with requirements of the EPZ, as noted in Section 0.

In the case of well works being conducted exclusion zones will apply for the period of the intervention. See SP-1190-2 and Section 3.4.

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3.4 Well Test Flaring Zoning

Well fluids with H2S in the composition will release SO2 if a well test unit is flaring. In the event that the flare was to be extinguished, there is also the potential for a ground level H2S release. All WTU flaring shall be conducted under the PDO PTW System (PR-1172). A Total Exclusion Zone and Special Precautions Zone for all well tests shall be established in line with SP-1190-2.

Well Test Flaring Zoning Working Requirements

Operational personnel shall ensure through the PDO PTW system, that the following zones are implemented. The requirements for the TEZ are over and above the requirements for the SPZ.

Total Exclusion Zone (TEZ) Special Precautions Zone (SPZ)

Entry only to WTU personnel, with use of full Self Contained Breathing Apparatus.

WTU PTW includes contact details for all personnel within SPZ.

Strictly no entry for Construction or Operations personnel.

Only entry for WTU personnel with persmission from Well Test Unit site responsible person.

Personnel in compliance with EPZ requirements.

Roads within this zone are to be temporarily sealed off by WTU personnel and provided with a yellow H2S warning sign for the duration of the flaring activities.

Wind direction to be monitored by the WTU and portable wind sock to be provided at worksite.

H2S & SO2 levels to be monitored around TEZ by WTU.

If H2S exceeds 10ppm or SO2 exceeds 2ppm, either

Flaring will be shut down, or

Evacuate non-associated personnel and WTU personnel don RPE.

TRIC includes flaring hazard.

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4 Working in H2S Facilities

4.1 Permit to Work

All work planned and executed shall be carried out in accordance with the Permit to Work (PTW) system. Refer to PR-1172, Permit to Work Procedure.

4.2 Job Planning, Hazard Identification and Assessment

It is the responsibility of the Permit Applicant and Responsible Supervisor to ensure a Job HSE Plan is produced to identify the activity related hazards. It is the responsibility of the Permit Holder to ensure a quality Toolbox Talk / Task Risk Identification Card (TRIC) discussion takes place, where the Job Safety Plan is discussed with the work party, and any additional hazards recorded on the TRIC form.

A Job HSE Plan shall be provided in compliance with PR-1172, and for Sour and Critical Sour facilities, the Job HSE Plan shall include the following in addition to the standard Job HSE Plan:

The potential sources of H2S under normal and upset conditions (planned and unplanned, or emergency releases),

Events that might release H2S into the work area,

The maximum concentration of H2S in the process stream(s) and the maximum concentration that might result at the work area, in the event of accidental or anticipated releases,

System integrity, reliability, and safeguards, including monitoring and alarm systems.

The TRIC discussion should include the contents of the Job HSE Plan together with:

Any potential where workers may be exposed to H2S in the course of their work,

Warning signs and/or barricades at each point of access where there is a potential for H2S exposure,

H2S testing and/or monitoring requirements,

Compliance to relevant Corporate Procedures,

Emergency response in the event of H2S release,

Access/egress – situations with limited access/egress and the potential for H2S exposure in confined / elevated spaces,

The need for escape or working breathing apparatus, safety person(s), rescue equipment (including resuscitators), and hazard warning signs shall be considered when carrying out work involving H2S,

Careful attention shall be given to details, such as equipment checks, access / egress (escape) routes, and obstacles.

In cases where the hazards have not been fully assessed and understood the job should not proceed.

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4.3 Numbers of Personnel on Site

The numbers of personnel that shall be allowed to be in a Critical Sour facility at any one instance shall be defined in the facility HSE Case, based on the site emergency response / contingency plan. This should also be provided for Sour Facilities.

Where the work is classed as ‘non-routine work’ i.e. major overhaul of equipment, additional personnel may be permitted on site provided the following criteria are met:

A documented Risk Assessment has been carried out,

And

The extra manning levels have been sanctioned by the Area Production Coordinator,

And

Required supervision is present and adequate for each team working in the restricted area,

And

Sufficient Respiratory Protective Equipment (CamLock Rig Walker or Escape Set) & personal gas detectors available,

And

A successful Escape and Evacuation drill is performed and a record made.

Non-essential work should be done offsite or deferred until a shutdown opportunity when the facility has been purged.

4.4 Activities requiring Breathing Apparatus (BA)

BA is required to be worn in a Sour or Critical Sour facility when performing any breaking of system containment until the work area has been tested for H2S and declared safe to proceed without BA (e.g. breaking flanges, opening of vessels, opening of pump casings, pipelines, etc). This is idenfied in a number of other specific proceedures.

For any BA activity, the Buddy System shall apply (Refer to PR-1081 – The Buddy System) and the Buddy must remain at a safe vantage point to provide aid or response.

BA is also required to be worn when:

Entering any Red Zone.

Working in an area where the concentration of H2S in air has been tested > 5 ppm or where a build-up of H2S could exceed the 5ppm limit (e.g. bunded areas and low-level areas). Refer to PR-1148 – Entry into a Confined Space.

Working in an area where the concentration of SO2 in air has been tested > 0.25 ppm or where a build-up of SO2 could exceed the 0.25ppm limit (e.g. bunded areas and low-level areas). Refer to PR-1148 – Entry into a Confined Space.

Performing wellhead activities, e.g. bleeding down to a pit, flowline operations etc. where H2S may be present in gas lift systems.

Entry to the roof of any tank which has PVVs or Blow Off Hatches which relieve to atmosphere, where the gas space has concentrations of 100ppm H2S or above.

Performing any sour sampling activity (refer to PR-1096 - Sampling of Oilfield Liquids and Gases Procedure).

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4.5 Gas Detection Methods

The following H2S detection methods can be selected for monitoring levels of H2S, based on the activity and hazards, as defined in the PTW:

Continuous gas monitoring in the immediate vicinity of the work using a properly calibrated

and maintained H2S monitoring device.

Intermittent measurements taken before and periodically during the work using a properly calibrated and maintained electronic H2S monitoring device or colorimetric detector tubes suitable for the range expected to be encountered. This method is typically used during turnarounds when multiple concurrent activities may be executed in an area without fixed H2S detection.

The fixed gas detection system shall not be used as a substitute for normal entry precautions into a high risk area, e.g. confined space entry.

Personal H2S monitors are used to alert the worker of a pre-set concentration of H2S, usually 10 ppm. Users shall verify the unit is within calibration date and perform the function test prior to use. Personal H2S monitors shall not be used as a substitute for normal entry precautions into a high risk area, e.g. confined space entry.

4.6 Departure from Site

On departure from site, the following shall be ensured:

The station entry register has been signed correctly,

personnel shall retrieve their H2S Card from the control board,

Access authorisation form has been cancelled (if required),

Permit to Work has been suspended at the end of the day or signed off if work is

completed.

Failure to comply with the above, may result in an unnecessary rescue operation being initiated in the event of an emergency.

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5 H2S Alarms and Facility Emergency Response

If you smell H2S, remove yourself from the work area immediately and report to a supervisor, even if no alarm has sounded.

All personnel shall respond as follows in the event of a personal H2S monitor alarming or the

Facility Alarm being sounded.

STOP Work

Hold Breath

DON Escape set or hood

CHECK Wind Direction

GO to Assembly Area to muster - across the wind from the leak source

COMPLY with any instructions given to them by the station operator / muster checker for

further action

In facilities where a Temporary Safe Refuge (TSR) exists, personnel should make their way to the

assigned TSR.

Advise the Area Authority, (CRO).

All Emergency Response will be in line with the relevant facility Emergency Response or Contingency Plans.

Shutdown / Blow down of the facilities shall be in line with the specific facility philosophy.

5.1 Rescue

Rescue procedures are outlined in CP-123 - Emergency Response Documents Part I - CoP. Any rescue shall be conducted by the station operations team in approved SCBA (SP-1234 & SP- 1190-5).

5.2 Emergency Procedures and Drills

Emergency Response Drills shall be conducted regularly to give all personnel the opportunity to practice the emergency response procedures. The requirement for this is outlined in CP-123 - Emergency Response Documents Part I - CoP.

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6 Appendix 1 - Operational H2S Management for Sour and Critical Sour Facilities

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6.1 Critical Sour Operational L2 Audit Checklist

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Level 2 Assurance: Terms of References (ToR)

Audit Title: Operational H2S Management for Critical Sour Facilities

Audit Date: Auditee:

Audit location: Audit Coordinator:

Documents to be reviewed:

- SP-1190- 1/2/3/4/5

Scope:

Review the Operational Compliance of the H2S Management System at site, for Critical Sour Facilities

Audit Team:

Contractor Representative:

Compliance mandatory: Yes No personal Targeted Yes No

Select Location(discipline):

□ Operations □ Contractor □------------- □ Commissioning □ Maintenance □ Exploration

□ Project □ Well services □-------------- □ North □ South □ Infrastructure

□ Gas □ Engineering □-------------- □ Logistic □------------- □ ------------------

Personnel Selected for Interview:

□ DTL □ CSR □ Operations Staff □ Contractor manager □ HSE advisor □ Permit holder □ Contractor Staff □ Journey manager □ ------------------ □

#

1190 Section

Audit Topic

Status

Source of evidence

GENERAL classification and zoning

1.

Part-1, 4.1

Has the Asset been classified for H2S in the last 4 years?

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

2.

Part-1/3 , 5.1/3.1

Are any Red or Yellow Zones identified at the facilities, in line with SP-1190-3 , 3.1.1 & 3.1.2

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

3.

Part 3

3.2

Has the facility been assessed for an EPZ? Is it applied?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

4.

Part 3

3.3

Has the facility been assessed for SIMOPS Zoning? Is it applied?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

General Critical Sour Requirements

5.

Part 3

4.6.19.4

Is the maximum number of persons allowed (POB) identified at site? Confirm site is in compliance.

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

6.

Part 3

4.6.19.5

Is there in a Facility Induction available?

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

7.

Part 3

4.6.19.2

Is there a sign outside the facility providing its H2S Classification?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

8.

Part 3

3.2.3.1

Is there a sign identifying the EPZ?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

9.

Part 3

4.8

Is there an Emergency Response or Contingency Plan in place

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

10.

Part 3

4.8.5

Plant Emergency Response Plan addresses H2S release scenarios?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

11. Part 4 Confirm the following at site: □Yes □No □ Document Inspection □ Record Analysis

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3.1.2 All persons carry either a:

‘Critical Sour Escape Set’, (CamLock Escape Set with Cowl hood)or a

‘Critical Sour Working and Escape Set’ (CamLock Rig Walker with Cowl Hood).

□ Process Witnessed □ Site Interview

12.

Part 4

2.2

Are all personnel provided with Personal H2S detectors?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

13.

Confirm that Personal H2S detectors are within calibration date □Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

14.

Part 4

2.2

Do all personnel have valid H2S Training Card?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

15.

Part 3

4.8.8

Life Saving (medical) equipment within the facility is provided as required?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

16.

Part 3

4.11

Standalone Operational HSE Case available?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Confirm additional Red Zone Requirements complied at site

17.

Part 3

4.6.20.1

Are Red Zones Identified by appropriate signage?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

18.

Part 3

4.6.20.2

Are Breathing Air Cascade or Mobile Air Skids provided to the Red Zones?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

19.

Part 4

3.1.1

The numbers of personnel in any one red zone is limited to 4 with one observer remaining outside the Red Zone at all times?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

20.

Part 4

3.1.1.1

Personnel entering the Red Zone do so under Breathing Air and using the Critical Sour ‘Working and Escape Set’(CamLock Rig Walker with Cowl Hood) or Full SCBA (CamLock Quest)?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

21.

Part 4

3.1.1.1

For sites using SCBA, maximum working duration has been assessed and recorded based on site trials?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

22.

Part 4

3.1.1

Any personnel working under Breathing Air can demonstrate that they have valid PDO Approved SCBA Training?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Confirm that additional EPZ Requirements complied at site

23.

Part 4

3.2.1

Confirm a valid PTW is available for work in the EPZ?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

24.

Part 4

3.2.1

JHSE Plan addresses H2S?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

25.

Part 4

3.2.1

Work party has communication method?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

26.

Part 4

3.2.1

Filter Type Escape Hoods are available for all personnel?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

27.

Part 4

3.2.1

Vehicles available for evacuation of all personnel?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

28.

Part 4

3.2.1

Works in proximity to ‘Process Area’, provided with H2S monitoring and / or trained rescue personnel and equipment?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

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Confirm that additional SIMOPS Zones Requirements are complied with at site

29.

Part4

3.3.1

MOPO available and in use?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

30.

Part4

3.3.1

Where appropriate, Contractor Self Evacuation demonstration or agreement on site rescue reached? Drills conducted?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

31.

Part 4

4.2

Job HSE Plan includes, full details of H2S sources & concentrations, potential releases scenarios, emergency response requirements.

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Confirm how Non-routine works which require the POB limit to be raised are managed. Ensure that:

32.

Part 4

4.3

A documented risk assessment has been carried out, and

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

33.

Part 4

4.3

The extra manning levels have been sanctioned by the Area Production Coordinator, and

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

34.

Part 4

4.3

Sufficient Respiratory Protective Equipment & Gas detectors available, and

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

35.

Part 4

4.3

Required supervision is present and adequate for each team working in the restricted area, and

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

36.

Part 4

4.3

A successful Escape and Evacuation drill is performed and recorded.

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Confirm with workers that they conduct the correct response in the event of:

37.

Part 4

5

They smell H2S?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

38.

Part 4

5

Their personal detector sounds at 10ppm?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

39.

Part 4

5

The plant alarm is sounded?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Well Test Flaring Control – Confirm at site

40.

Part 4

3.4.1

Total Exclusion Zone and Special Precautions Zone Calculated?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

41.

Part 4

3.4.1

H2S TEZ Signs provided in line with SP-1190-2

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

42.

Part 4

3.4.1

Confirm Only WTU personnel – using SCBA – are authorised to enter TEZ

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Special Precautions Zone – confirm that the following are implemented

43.

Part 4

3.4.1

WTU PTW provides contact details of other parties in SPZ

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

44. Part 4 EPZ requirements are in place, specifically - filter hood,

evacuation vehicle, personal H2S detector, H2S Training, □Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

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3.4.1 Communication

45. Part 4

3.4.1

WTU has wind sock and monitors wind direction

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

46.

Part 4

3.4.1

H2S and SO2 detection and monitoring in place

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

47.

Part 4

3.4.1

TRIC includes the flaring hazard

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

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6.2 Sour Operational L2 Audit Checklist

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Level 2 Assurance: Terms of References (ToR)

Audit Title: Operational H2S Management for Sour Facilities

Audit Date: Auditee:

Audit location: Audit Coordinator:

Documents to be reviewed:

- SP-1190- 1/2/3/4/5

Scope:

Review the Operational Compliance of the H2S Management System at site, for Critical Sour Facilities

Audit Team:

Contractor Representative:

Compliance mandatory: Yes No personal Targeted Yes No

Select Location(discipline):

□ Operations □ Contractor □------------- □ Commissioning □ Maintenance □ Exploration

□ Project □ Well services □-------------- □ North □ South □ Infrastructure

□ Gas □ Engineering □-------------- □ Logistic □------------- □ ------------------

Personnel Selected for Interview:

□ DTL □ CSR □ Operations Staff □ Contractor manager □ HSE advisor □ Permit holder □ Contractor Staff □ Journey manager □ ------------------ □

#

1190 Section

Audit Topic

Status

Source of evidence

GENERAL classification and zoning

1.

Part-1, 4.1

Has the Asset been classified for H2S in the last 4 years?

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

2.

Part-1/3 , 5.1/3.1

Are any Yellow Zones identified at the facilities, in line with SP- 1190-3, 3.1.2

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

3.

Part 3

3.2

Has the facility been assessed for an EPZ? Is it applied?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

4.

Part 3

3.3

Has the facility been assessed for SIMOPS Zoning? Is it applied?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

General Sour Requirements

5.

Part 3

4.6.19.3

Is Access Control in place, in line with SP-1190?

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

6.

Part 3

4.6.19.2

Is there a sign outside the facility providing its H2S Classification?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

7.

Part 3

3.2.3.1

If applicable, Is there a sign identifying the EPZ?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

8.

Part 3

4.8.5

Plant Emergency Response Plan addresses H2S release scenarios?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

9.

Part 4

3.1.2

If Yellow Zones in place, Confirm the following at site:

All persons entering a Yellow Zone carry either a:

‘Critical Sour Escape Set’, or a

‘Critical Sour Working and Escape Set’.

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

10.

Part 4

2.2

Are all personnel provided with Personal H2S detectors?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

11.

Confirm that Personal H2S detectors are within calibration date □Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

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12. Part 4

2.2

Do all personnel have valid H2S Training Card?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

13.

Part 3

4.8.8

Life Saving (medical) equipment within the facility is provided as required?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

If appropriate: Confirm that additional EPZ Requirements are complied with at site

14.

Part 4

3.2.1

Confirm a valid PTW is available for work in the EPZ?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

15.

Part 4

3.2.1

JHSE Plan addresses H2S?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

16.

Part 4

3.2.1

Work party has communication method?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

17.

Part 4

3.2.1

Filter Type Escape Hoods are available for all personnel?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

18.

Part 4

3.2.1

Vehicles available for evacuation of all personnel?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

19.

Part 4

3.2.1

Works in proximity to ‘Process Area’, provided with H2S monitoring and / or trained rescue personnel and equipment?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Confirm that additional SIMOPS Zones Requirements are complied with at site

20.

Part4

3.3.1

MOPO available and in use?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

21.

Part4

3.3.1

Where appropriate, Contractor Self Evacuation demonstration or agreement on site rescue reached? Drills conducted?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

22.

Part 4

4.2

Job HSE Plan includes, full details of H2S sources & concentrations, potential releases scenarios, emergency response requirements.

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

If appropriate: Confirm how Non-routine works which require the POB limit to be raised are managed. Ensure that:

23.

Part 4

4.3

A documented risk assessment has been carried out, and

□Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

24.

Part 4

4.3

The extra manning levels have been sanctioned by the Area Production Coordinator, and

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

25.

Part 4

4.3

Sufficient Respiratory Protective Equipment & Gas detectors available, and

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

26.

Part 4

4.3

Required supervision is present and adequate for each team working in the restricted area, and

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

27.

Part 4

4.3

A successful Escape and Evacuation drill is performed and recorded.

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Confirm with workers that they conduct the correct response in the event of:

28.

Part 4

5

They smell H2S?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

29. Part 4

Their personal detector sounds at 10ppm? □Yes □No □ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

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Effective: Jan-19

5

30. Part 4

5

The plant alarm is sounded?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

Well Test Flaring Control – Confirm at site

31.

Part 4

3.4.1

Total Exclusion Zone and Special Precautions Zone Calculated?

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

32.

Part 4

3.4.1

H2S TEZ Signs provided in line with SP-1190-2

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

33.

Part 4

3.4.1

Confirm Only WTU personnel – using SCBA – are authorised to enter TEZ

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

SPZ – confirm that the following are implemented

34.

Part 4

3.4.1

WTU PTW provides contact details of other parties in SPZ

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

35.

Part 4

3.4.1

EPZ requirements are in place, specifically - filter hood, evacuation vehicle, personal H2S detector, H2S Training, Communication

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

36.

Part 4

3.4.1

WTU has wind sock and monitors wind direction

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

37.

Part 4

3.4.1

H2S and SO2 detection and monitoring in place

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

38.

Part 4

3.4.1

TRIC includes the flaring hazard

□Yes □No

□ Document Inspection □ Record Analysis □ Process Witnessed □ Site Interview

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Petroleum Development Oman LLC Version: 5.0

Effective: Jan-19

6.3 Audit Report

1. Summary of Audit

This report presents the findings and recommendations of the Level 2 audit of the H2S Operations Management System carried out on / date. The scope of the audit included and covers PDO, contractors and sub- contractors. This audit was part of PDO HSE assurance plan assisted by the corporate HSE. The audit is in support to the PDO efforts and actions to fully implement and effectively sustain H2S Management across PDO Operations.

There was positive evidence of the implementation of SP-1190 Series and is listed below in section 2 of this report.

This audit has also identified some areas where material gaps exist which require preventative actions as listed in section 3 of this report. In order to ensure that these gaps are closed expeditiously and sustained, close monitoring of the actions by the leadership need to continue. The actions shall be entered into the PIM system.

2. The Positive Observations example:- - A,

- B

- C

- etc.

3. Action plan:

Finding #

Finding

Actions

A. Party

Target date

PIM #

.

Auditor/Reference Indicator Date: Counter Sign Auditee / Representative

Page 33 SP-1190-4 H2S & SO2 Management – Operations Printed 17/02/19

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