Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] WELL ENGINEERING & OPERATIONS DISMANTLING SAFETY CASE ASSESSMENT TEMPLATE Work Instructions Topic specialists should use this template to record their assessment of the Well Engineering and Operations aspects of a dismantling safety case. Assessment should be against the requirements of SCR2015. Exemplar Approach - This template should be used in accordance with the scope of the Assessment Instructions when the topic is included for assessment. An exemplar approach may be sufficient if some material has been previously accepted and has not materially changed. For example a CMAPP or SEMS from an existing, accepted safety case. The template is one of a series covering all assessment topics, which together form a complete record of the safety case assessment and create evidence of how the decision to accept the case, or not, was reached. The templates identify the specific regulatory requirements of SCR2015 for the topic and indicate what the competent authority expects to find within a safety case to demonstrate that those requirements are met. The template complements the published guidance that supports the regulations and topic sector guidance. The templates are available to promote transparency and assist duty holders in drafting submissions. Green text indicates regulatory requirements that are new in SCR2015. Black text represents regulatory requirements that are contained in both SCR2005 and SCR2015. Non Acceptance Issue - A Non Acceptance Issue (NAI) is a deficiency in the demonstration made within a safety case, which, if not resolved, will prevent the case from being accepted under the relevant statutory provisions. Non Acceptance Issues must be sent by a formal letter to the duty holder requiring them to be dealt with in the appropriate manner, giving the duty holder a clear understanding of how to address the deficiency. Clarification - A Clarification is an explanation provided by a duty holder on request during assessment to enable the assessing Inspectors to be confident of their interpretation of the information in a safety case. Clarifications are a routine part of assessment work and should be raised with a duty holder promptly. Clarifications do not require formal letters. Communicating by telephone and email is sufficient. A meeting between the duty holder and relevant topic specialists may also be appropriate in some circumstances for clarifications. Clarification is not a first stage before raising non-acceptance issues. Any aspect that could credibly lead to a Non-Acceptance Issue should be raised as such in the first instance. TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 1 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Relevant Pre-Existing Guidance APOSC Principles: Principle 1 The factual information should meet the SCR2015 requirements and provide sufficient detail to support the arguments made in the case Management of health and safety Principle 2 The safety case should demonstrate that the management system is adequate to ensure compliance with the relevant statutory provisions… Principle 3 The management system should show an appropriate level of control during each phase of the installation life cycle, including design, construction, commissioning, operation, decommissioning and dismantlement Major accident hazard identification Principle 4 A systematic process should be used to identify all reasonably foreseeable major accident hazards that apply to the installation, together with potential initiating events or sequences of events Major accident risk evaluation Principle 5 The methodology and evaluation criteria adopted for major accident risk assessment should be clear Principle 6 Any criteria for eliminating the less significant risks from detailed consideration in the major accident risk evaluation should be explained Principle 7 The assessment should take account of people exposed to exceptional risks Principle 8 The major accident risk evaluation should take account of human factors TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 2 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Principle 9 Conclusions reached in risk assessment processes should take uncertainty into account Principle 10 The identification of risk reduction measures should be systematic and take into account new knowledge Principle 11 The reasoning behind the choice of risk reduction measures to be implemented should be described. Decisions on implementation should take reasonable practicability into account Principle 12 Risk reduction measures identified, as part of the risk assessment, should be implemented if they are reasonably practicable Principle 13 In deciding what is reasonably practicable, the case should show how relevant good practice and judgement based on sound engineering, management and human factors principles have been taken into account Principle 14 Where remedial measures are proposed to reduce risk, the timescale for implementing them should take account of the extent of such risks and any practical issues involved Major accident risk management Principle 15 Measures taken to manage major accident hazards should be described Principle 16 The safety case should explain how inherently safer design concepts have been applied in the design decisions taken Principle 17 The measures for preventing major accident hazards should take account of the various activities undertaken during the installation's current phase of operation Principle 18 Appropriate detection measures should be provided for any reasonably foreseeable event requiring an emergency response TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 3 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Principle 19 Appropriate control and mitigation measures should be provided to protect personnel from the consequences of a major accident Principle 20 Arrangements for controlling an emergency should take account of likely conditions during emergency scenarios Emergency response Principle 24 Evacuation and escape arrangements should be integrated in a logical and systematic manner, taking account of the environment in which they may need to function Combined operations Principle 28 The management system should address the additional risks associated with combined operations Principle 29 A systematic approach should be taken to assessing the impact of combined operations on the conclusions of the operational safety case for each installation Principle 30 A systematic approach should be taken to identifying and assessing any additional major accident hazards arising from combined operations. These can be new hazards or changes to existing hazards Principle 31 The measures for emergency response should be appropriate to the particular combined operation GASCET Chapters: 2.4.1 Wells risk evaluation and management This Section provides guidance for the assessment of safety case content with respect to wells and well systems, from hazard identification through to consequence determination, including risk management measures. TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 4 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Other Guidance Reference: The following documents are industry guidance that can aid in determining if the duty holder is following good industry practice: Well Lifecycle Practices Forum Guidelines for the suspension and abandonment of wells Guidelines on qualification of materials for the suspension and abandonment of wells Guidelines for well-operators on competency of well-examiners Guidelines for well-operators on well examination Guidelines on competency for wells personnel Guidelines on relief well planning for offshore wells Well life cycle integrity guidelines Guidelines on BOP Systems for Offshore Wells Energy Institute Model code of safe practice Part 17 Vol 1,2 & 3 – High Pressure High Temperature Wells Model code of safe practice Part 15 – Area classification code for installations handling flammable fluids Guidelines for offshore oil and gas installations that are not permanently manned TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 5 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] 1. Safety case for dismantling a fixed installation requirements a) SCR2015 Schedule 8 – Particulars to be included in a current safety case in respect of the dismantling of a fixed installation Assessment Criteria / Minimum Information SC Ref NAI Clarification SCR2015 Regulatory Requirement 1. The name and address of the operator of the installation. 2. The maximum number of persons expected to be on the installation at any time during its dismantling. 4. The dates on which dismantling is expected to commence and finish. 6. In the case of the dismantling of a fixed production installation— (a) information on the means of isolating all hazardous substances and, in the case of any well connected to the installation, the permanent sealing of the well from the installation and the environment; (b) a description of the risks of a major accident associated with the decommissioning of the installation to workers and the environment, the total exposed population, and the risk control measures; (c) information on the emergency response arrangements to secure safe evacuation and rescue of personnel and to maintain control systems for preventing a major accident to the environment. 7. A description of how the operator will comply with regulation 4(1) of the PFEER Regulations with regard to the dismantling of the installation. 8. A description of arrangements made for protecting persons on the installation from toxic gas at all times other than during any period while they may need to remain on the installation following an incident which is beyond immediate control. 9. Sufficient details to update the description of the internal emergency response arrangements— (a) in the case of a production installation, under paragraph 21 of Schedule 6; or (b) in the case of a non-production installation, paragraph 17 of Schedule 7. Criteria Met / Not Met - Assessment Comments Para 1 - Does the safety case have the name and address of the operator of the installation? If applicable has a separate Well Operator been identified? (APOSC Principle 1) Para 2 - Does the safety case identify who shall be aboard during well abandonment operations? (APOSC Principles 1 & 2) Para 4 – Does the safety case contain the dates when well abandonment operations are expected to commence and finish? (APOSC Principle 1) TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 6 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Para 6(a) – Does the safety case contain information on the means of isolating any well connected to the installation by the permanent sealing of the well from the installation and the environment; Does it contain details of the following: - Manning philosophy for well abandonment operations Well abandonment operations organisation Competency / training in well abandonment operations Selection and control of well operations contractors Installation and subsea wells requiring to be abandoned Well abandonment schematic / description and design philosophy Reservoir conditions Reservoir fluid properties Abandonment problem history / experience If different from that in the existing safety case details about: Platform rig being used or a hydraulic workover unit, modular rig etc. Rig power systems Drilling equipment Fluid handling equipment Temporary hydrocarbon handling equipment Derrick / rig floor Well operations lifting equipment Installation hazardous areas Well pressure control equipment Well shut-in systems Protection against dropped / swinging load Subsea protection systems (APOSC Principle 2) Para 6(b) – Does the safety case contain a description of the risks of a wells related major accident associated with the decommissioning of the installation to workers and the environment, the total exposed population, and the risk control measures (APOSC Principle 15) TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 7 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] Para 6(c) - What arrangements are in place for controlling a well related emergency. What are the roles and responsibilities during well control incidents? (APOSC Principle 20) Para 7 - Does the safety case provide details of the escape routes from well operations areas? (APOSC Principle 24) Para 8 - Does the safety case contain a description of arrangements made for protecting persons on the installation from toxic gas at all times other than during any period while they may need to remain on the installation following an incident which is beyond immediate control Does it contain details of the following? Well operations fire, gas and hydrogen sulphide detection. (APOSC Principle 18) Para 9(a) & (b) - How are well abandonment operations emergency situations included in the internal emergency response arrangements. (APOSC Principle 20) TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 8 of 9 Document Title: Well Engineering & Operations Dismantling Safety Case Assessment Template Logos: DECC / HSE / OSDR Logos Case Title - [Safety Case Title] Duty Holder – [Company Name] COIN Numbers - [Case] / [SVC Number] Topic Assessor – [Name] WELL ENGINEERING AND OPERATIONS REQUIREMENTS - ASSESSMENT SUMMARY NAI – Non Acceptance Issue SCR2015 Regulatory Requirement Clarification Required NAI Required Conclusion 1. Fixed Installation Safety Case for Dismantling Requirements a) Schedule 8 – Particulars to be included in a current safety case in respect of the dismantling of a fixed installation b) c) TRIM: 2015/273928 Revised: 22 July 2015 Owner: ED 4.4 Page 9 of 9