KP4: Ageing and Life Extension – Process Integrity Onshore Template INSTALLATION or DUTYHOLDER Key Persons interviewed DATES(S) Company Summary of Inspection Traffic Lights IMT and INSPECTOR(S) Position Red 6 5 Amber Green W 4 3 2 1 0 Section A: Ageing and Life Extension (ALE) Policy and Leadership Section B: ALE - Organising Section C: ALE - Planning and Implementing Section D: ALE - Measuring Performance Section E: ALE - Auditing and Reviewing Performance Summary of Inspection Findings: HSE Action taken: Rev. 2 10 June 2011 Page 1 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section A: Ageing and Life Extension (ALE) - Policy (Questions for senior management – typically Operations Manager, Asset Integrity Manager, Process Engineering Technical Authority) Principal Questions: 1) What do you consider the ageing and life extension issues to be for process safety? 2) Can you give some examples where you have encountered issues regarding ageing and life extension? 3) How did you deal with these? 4) Describe the policies that senior management has in place to ensure that: a) the design basis for topsides plant and equipment is suitable for current and projected production profiles, and fluid composition; b) modifications to the process system are integrated with the existing production operations; c) performance standards for safety critical elements on existing (as well as new) process systems are suitable and sufficient for the revised functional specification; d) improvements in health, safety, and welfare standards are implemented where reasonably practicable in compliance with current HSE and Industry guidance, and applicable national and international standards and codes of practice; e) the mechanical integrity of systems containing hazardous materials is sound; f) obsolescence of software and hardware systems for control and instrumentation for existing systems are identified, and alternatives sourced; g) redundant equipment that represents significant congestion and aggravated explosion damage, or barrier to emergency response are removed where this is reasonably practicable; h) failure of one or more prevention or mitigation measures does not increase risk to the most exposed group of workers to intolerable levels for continued production operations 5) What are the Key Performance Indicators used to indicate the asset integrity status to Senior Managers? Benchmarks sought in replies: Awareness of original design life of plant and equipment Awareness of internal and external corrosion, corrosion under insulation/passive fire protection and erosion Awareness of vibration issues leading to fatigue especially small bore tubing Rev. 2 10 June 2011 Page 2 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Knowledge of relevant changes in regulation, regulatory guidance, industry guidance, international standards and codes of practice Knowledge of relevant operational experience Incident investigation and dissemination of findings Incident reporting of near misses as well as RIDDOR and HCRs Policy on ageing and life extension covering the projected lifetime of the asset Periodic review of design basis triggered by trends in production profile, or time elapsed from previous review Updated heat and material balances Updated material selection guide Key documentation P&IDs, Cause and Effect Diagrams, Hazardous Area Classification Drawings, Operating Procedures etc. are revised to reflect changes Formal Safety Assessments, HAZID, HAZOP, Fault Tree Analysis, Failure Modes and Effects Criticality Analysis triggered by policy on ALE Safety Integrity Levels are conducted/reviewed to confirm no changes in functional, reliability/availability, or vulnerability specifications A continuing programme of non-destructive testing and visual inspection methods is used to verify adequate wall thickness, and absence of defects A flexible hose register is maintained A seeps, weeps, and leaks register is maintained A defined life repair register is maintained, audited and reviewed A log of inhibits and over-rides is maintained, audited, and reviewed. An operational risk assessment process is in place Examples of leading (e.g. number of total PSVs successfully tested in a period), and lagging (e.g. number of faults discovered during testing of PSVs) indicators provided Rev. 2 10 June 2011 Page 3 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section A: Ageing and Life Extension (ALE) - Policy Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served Rev. 2 10 June 2011 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 4 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section B: ALE - Organising (Questions for senior management – typically Operations Manager, Asset Integrity Manager, Process Engineering Technical Authority) Principal Questions: 1) Who is responsible for: 2) 3) 4) 5) 6) 7) a) Loss of Containment prevention; b) Operational Risk Assessment; c) Management of Change; d) Maintenance and Testing of safety critical Plant Protection Systems? How do these persons fit into the organization? How is safety culture on ALE encouraged? How are views on ALE communicated to and from the workforce How do you document Operational Controls and Maintenance Records How do you assure the competency of personnel involved in the management, operation, inspection, and maintenance of plant and equipment? How is competence assured for contractors? Benchmarks sought in replies: An understanding of ageing issues An understanding of life extension issues Well defined roles and responsibilities Wide consultation with the workforce Ownership of the management system Systems and procedures for change control Arrangements to secure corporate memory Systems and procedures for document control Systems and procedures for Operation Systems and procedures for Maintenance management Competence assurance systems in place for operations and maintenance personnel Competence assessment system for contractors Rev. 2 10 June 2011 Page 5 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section B: ALE - Organising Onshore Management: Offshore Operations: HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served Rev. 2 10 June 2011 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 6 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section C: ALE - Planning and Implementing (Questions for senior management – typically Process Engineering Technical Authority, Asset Integrity Managers, EH & S Managers, Project Managers, OIMs) Principal Questions: 1) 2) 3) 4) 5) 6) 7) 8) What is your system for identifying hazards? How do you assess the risk? How do you establish the protective and mitigation measures? How do you prioritise the work? Is maintenance, inspection, or testing contracted out? How is implementation controlled? How is change controlled? How does age trigger the above processes Benchmarks sought in replies: Formal safety assessment - Hazard and Operability Study/Hazard Analysis, Failure Modes and Effects Criticality Analysis Asset register of safety critical elements, Inherently Safer Design, Risk Graph, Layers of Protection Analysis, Fault Tree Analysis Risk Based Inspection, Campaign, Breakdown, Condition Monitoring Periodic replacement, testing and inspection Operating and Maintenance records, including service life Incident data, internal/external Risk targets, most vulnerable personnel exposure, frequency vs. consequence Integrated system Work packs, work orders, operating instructions, written schemes of examination, maintenance routines, performance standards Change requests, approvals, tracking register, management of change procedures, verification Procedures for changes in: plant and equipment safe operating envelopes; plans, procedures and key documentation; people and organisation; major accident hazards; regulatory policy; guidance, and international codes and standards Design life is documented Key Performance Indicators are identified Rev. 2 10 June 2011 Page 7 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section C: ALE - Planning and Implementing Onshore Management: Loss of containment Operational Risk Assessment Process modifications/additions Offshore Operations: N/A HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served Rev. 2 10 June 2011 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 8 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section D: ALE - Measuring Performance (Questions for senior management – typically Process Engineering Technical Authority, Maintenance Managers, Production Supervisors) Principal Questions: 1) What codes, standards, recommended practices, guidelines, etc. have 2) 3) 4) 5) 6) been identified as relevant to ageing & life-extension (ALE) and asset integrity management (AIM)? What parameters are measured during operation/inspection? Where are the performance standards recorded? How do you track progress for testing/inspection? What are your key leading and lagging performance indicators? How are these communicated to senior management? Benchmarks sought in replies: Benchmarking of design against current standards Inspection methods and techniques are used to detect ageing i.e. creep, cracking, corrosion, damage, and wear More detailed inspection required if life extension is contemplated or deterioration from ageing is detected Register of weeps, leaks, and breaks i.e. minor, significant and major hydrocarbon releases to inform the life extension analysis Data measurement which does not meet the performance standards used to determine remaining or extension to life Formal life-extension studies are performed Use made of trends of incident, accident and near-miss data Senior Management is aware of the status and condition of process plant and equipment Rev. 2 10 June 2011 Page 9 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section D: ALE - Measuring Performance Onshore Management: Loss of containment Operational Risk Assessment Process modifications/additions Offshore Operations: N/A HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served Rev. 2 10 June 2011 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 10 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section E: ALE - Auditing and Reviewing Performance (Questions for senior management – typically Asset Integrity Manager, Maintenance Manager, Operations Manager, OIM, Process Engineering Technical Authority) Principal Questions: 1) How does the verification scheme address the ALE of process plant & equipment (static & rotating) safety critical elements (SCEs)? 2) Who conducts a review of key performance indicators? 3) How frequently? 4) What results from such a review? Benchmarks sought in replies: A degree of independence is included in the audit and review arrangements The outcome of audits and reviews results in an updated ageing and life extension strategy Proposed changes are recorded / logged assessed and approved before implementation Rev. 2 10 June 2011 Page 11 of 12 KP4: Ageing and Life Extension – Process Integrity Onshore Template Section E: ALE - Auditing and Reviewing Performance Onshore Management: Loss of containment Operational Risk Assessment Process modifications/additions Offshore Operations: N/A HSE Comments: HSE Action taken: Traffic Light Score SERIOUS NONCOMPLIANCE Court proceedings recommended 6 SIGNIFICANT NONCOMPLIANCE Enforcement Notice Served Rev. 2 10 June 2011 5 GENERAL NONCOMPLIANCE Letter & changes made to intervention 4 PARTIAL COMPLIANCE GENERAL COMPLIANCE GENERAL COMPLIANCE Letter Verbal advice No findings 3 2 1 NOT INSPECTED 0 Page 12 of 12