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North Sea SPU (UK)

Integrity Management Strategy


Well Operations Integrity
Management Strategy
Issuing
Authority:
Document
Authority:
Margaret Copland
SPU Wells Technical Authority
Document
Administrator:
Janet Ross
SMS Advisor
Applicability: North Sea SPU (UK)
Issuing
Department:
Engineering Control Tier: 2
First Issue Date: November 2008 Revision No: Issue 1
Revision Date: Review Required By: November 2011
Revision Summary: First issue.
For further information contact DCC at ODL on 01224 628018 or dcc@odl.co.uk.
Document Location: Documentum/ABZ Federal/SMS
NSSPU-IMS-003

Well Operations Integrity Management Strategy NSSPU-IMS-003
Contents
Paragraph Page
1 Introduction 1
2 Scope 2
2.1 Purpose 3
2.2 Project Phase (Design, Construct, Commission) 4
2.3 Well Operations Phase 6
3 Organisation 8
3.1 Ownership 8
3.2 Technical Hierarchy Model 9
3.3 Roles and Responsibilities 9
4 Risk Management 11
4.1 General 11
4.2 Management of Safety Critical Equipment 12
4.3 Management of Non-safety Critical Equipment 14
5 Integrity Management Process 15
6 Management of Change 17
7 IM Documentation and Data 18
8 Performance Management 19
8.1 KPIs 19
8.2 KPI Management 19
8.3 Annual Integrity Statement 19



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NSSPU-IMS-003 Well Operations Integrity Management Strategy

ii November 2008 Issue 1
Contents (contd)
Table Page
1 ETPs Relevant to Wells 5


Figure
1 Life-cycle Responsibility 8
2 Logic for Identification of Safety Critical Activities 13
3 Integrity Management Process 16
4 Documentation and Data Support 18


Addendum 1 Technical Hierarchy Model
Addendum 2 Performance Standard Example
Addendum 3 UK Sector RACI Chart
Addendum 4 Norway Sector RACI Chart


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Well Operations Integrity Management Strategy NSSPU-IMS-003
1 Introduction
This document details how Well Services have a strategy in place, which demonstrates
conformance with the Integrity Management Standard: Implementation in E&P
document.
The Group Integrity Management (IM) Standard has been developed to help prevent and
mitigate integrity-related losses associated with safety, environment, business and
reputation through the integration of:
The Process Safety/Integrity Management (PSIM) Standard (2001)
The Major Accident Risk (MAR) assessment process, introduced in 2002
The appointment of Engineering Authorities (EAs) and Technical Authorities (TAs)
The application of Engineering Technical Practices (ETPs)
The Integrity Management Standard: Implementation in E&P document defines specific
minimum requirements against each of the ten elements highlighted in the BP Group IM
Standard. Conformance with the 10 elements are covered in detail within this document.
Element 1 Accountabilities
Element 2 Competence
Element 3 Hazard Evaluation and Risk Management
Element 4 Facilities and Process Integrity
Element 5 Protective Systems
Element 6 Practices and Procedures
Element 7 Management of Change
Element 8 Emergency Response
Element 9 Incident Investigation and Learning
Element 10 Performance Management and Learning
The Standard requires that IM is a line responsibility and that Major Projects and
Strategic Performance Units (SPUs) clearly identify the roles and responsibilities of the
personnel who are accountable for delivering conformance.

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NSSPU-IMS-003 Well Operations Integrity Management Strategy
2 Scope
This document covers all wells in the North Sea SPU. It defines the requirements to
assemble a demonstrable, auditable system for the delivery of well integrity across all
ten elements of the IM Standard. Non BP owned Well intervention equipment is
outwith the scope of this document and is managed through Control of Hired and
Transportable Equipment (UKCS-SOP-005).
Although this document relates to wells in general, the primary focus in the first stage of
implementation will be Safety Critical Equipment (SCE) integrity to align with the IMS
implementation plan. Although links may exist with other integrity systems (eg platform
shut-down systems, control panels etc.) the management of these systems are covered
by other IM strategies.
A generic listing of well related Safety Critical Equipment (SCE) that is covered by this
strategy is listed below:
Tier 3 Strategies for Well Services Safety Critical Equipment
Wellheads/Production Trees and Sub-Sea Trees
Down Hole Safety Valves (DHSVs) and Annulus Safety Valves (ASVs)
Casing and Tubing
Pressure Control Equipment (PCE) (which is BP owned including portable Well
Control Panels)
Each asset shall identify safety critical elements pertaining to their area of responsibility.
Safety critical equipment for most assets in the North Sea SPU, is recorded in Maximo,
where records are held of all planned maintenance and testing, carried out to satisfy the
performance standards, set against the SCE`s. For the Norwegian sector, the system of
recording SCE`s is through the WORKMATE system, for Foinaven STAR is the system
that is used. Safety Critical Equipment Assignment Standard (UKCS-TS-019) defines
what equipment should be identified as safety critical.
A well is defined as the pressure containment envelope which therefore includes casing
and tubing strings, downhole components, wellheads and xmas trees including tree
valves and actuators.
Conductors are considered structural elements and are included in the Offshore
Structural Integrity Delivery Requirements (NSSPU-GP-66-00-1).
Gauges and instrumentation are not part of the well envelope and are covered by
instruments Fire and Gas Detection (NSSPU-GMS-I01).

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Well Operations Integrity Management Strategy NSSPU-IMS-003
2.1 Purpose
The purpose of this strategy is to provide a system for the identification and control of
risks associated with the design, construction, commissioning, operation and
maintenance of safety critical wells equipment.
In conformance with the objectives of the IM Standard, the Wells IM Strategy will:
Confirm that materials, equipment and structures in use, are fit for purpose
Avoid loss of containment by stringent practices and procedures
Maintain mechanical and pressure integrity through assurance process
Prevent major incidents that result from failure of equipment and systems
Establish safe operating limits and confirm operation within these limits
The strategy is developed around four fundamental processes:
(a) Risk Assessment, Verification, Mitigation and Assurance.
Risk Assessment Process to identify hazards affecting the integrity of the
wells/platform from well service activities and the use of temporary equipment
Mitigation Control Process to manage the associated risks to As Low As
Reasonably Practicable (ALARP)
Verification of the procedures and processes relating to well operations
activities
Life-cycle assurance (maintenance, inspection, repair and replacement) of the
wells, pressure control equipment which is bp owned, trees and wellheads
(b) Applicable Regulatory requirements/Guidance.
(i) United Kingdom Continental Shelf (UKCS) Legislative Requirements
Management of Health and Safety at Work Regulations
Safety Case Regulations (SCR)
Lifting Operations and Lifting Equipment Regulations (LOLER)
Provision and Use of Work Equipment Regulations (PUWER)
Design and Construction Regulations (DCR)
Prevention of Fire and Explosion, and Emergency Response Regulations
(PFEER)
Borehole Regulations (Wytch Farm)
(ii) Norwegian Requirements
The Management regulations
Guidelines relating to management in the petroleum activities
The Activities Regulations
Guidelines relating to conduct of activities in the petroleum activities

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NSSPU-IMS-003 Well Operations Integrity Management Strategy
The Facilities Regulations
Guidelines relating to design and outfitting of facilities etc. in the
petroleum activities
Norsok D-010, well integrity in drilling and well operations
Guidelines for the application of IEC 61508 and IEC 61511 in the
petroleum activities on the Norwegian continental shelf
(iii) BP Governing Documents
Drilling and Well Operations Practices (DWOP)
Engineering Technical Practice (ETP)
Integrity Management Standard
(c) Design and Construction Phases.
Formal assurance should be provided in the well handover package from the
drilling team that verifies the design and construction of the well has been carried
out using good engineering practice and complies with the regulatory requirements
and BP governing documents.
(d) Verification and Annual Assurance Review.
Element 10 of the IM standard, calls for Implementation of verification and audit
programmes to confirm IM requirements are being delivered and that learnings
are fed into the continuous improvement cycle. Well services meet this
requirement by:
Review close out of PMs which relate to well head maintenance,
PCE maintenance and testing and ASV/DHSV testing
Audit of maintenance records relating to safety critical equipment
Audit of adherence to performance standards
Review of any actions raised on well integrity issues
The implementation of this strategy will ensure conformance to the requirements of
Getting Health, Safety and Environment Right (GHSER) and the IM Standard.
2.2 Project Phase (Design, Construct, Commission)
Technical Integrity is a key aspect of the project phase to deliver fit for purpose wells,
as stipulated to the IM Standard, Minimum Requirement 4.3:
Major Projects and Drilling shall hand over to the Operating BU full life-cycle IM
strategiesthat conform with Engineering Technical Practices.

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Well Operations Integrity Management Strategy NSSPU-IMS-003
It is the responsibility of the project/drilling team to demonstrate that integrity is
achieved through design, construction and commissioning of the wells in accordance
with the IM Standard. Some of the processes that lead to delivering the appropriate
level of integrity during the Project Phase (and may deliver integrity assurance
throughout the life-cycle) are:
The clear definition of roles, responsibilities and accountabilities
The application of ETPs and/or International Standards
Inherent safety features included in the design of well equipment
Formal Safety Assessment (FSA)
Hazard and Operability Study (HAZOP)
Quantitative Risk Assessment (QRA)
Project Health, Safety and Environmental review (pHSEr)
Identification and management of Safety Critical Equipment (SCE)
The rigorous application of the IM Standard
Well handover documentation
2.2.3 Engineering Technical Practices
The design of wells, facilities, structures and equipment, is extensively covered
in company ETPs, Site Technical Practices (STPs), Industry codes and Standards.
The following ETPs are relevant.

ETP
Number
ETP Name
Design and
Construction
Phase
Operations
Phase
GP 10-01 Casing and Tubing Design * *
GP 10-05 Directional Drilling and Surveying *
GP 10-10 Well Control * *
GP 10-15 Pore Pressure Prediction *
GP 10-16 Pore Pressure Detection During Well
Operations
*
TBC Shallow Hazards *
TBC Well Intervention Risers/Pressure
Control
* *
GP 10-25 Waste and Fluids Pollution Risk
Mitigation
*
GP 10-30 Hydrogen Sulphide and Hazardous
Materials in Well Operations
* *
Table 1 ETPs Relevant to Wells

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NSSPU-IMS-003 Well Operations Integrity Management Strategy
ETP
Number
ETP Name
Design and
Construction
Phase
Operations
Phase
GP 10-35 Well Operations *
GP 10-36 Breaking Containment * *
TBC Well Management *
TBC Drilling Rig Audits and Rig Acceptance * *
(Intervention
Vessels)
GP 10-80 Well Testing * *
TBC Moving and Securing of Mobile
Offshore Drilling Units
*
GP 10-50 Engineered Equipment * *
GP 10-60 Zonal Isolation Requirements during
Drilling Operations and Well
Abandonment and Suspension
* *
GP 10-75 Simultaneous Operations * *
TBC Working with Pressure * *
Table 1 ETPs Relevant to Wells (contd)
2.3 Well Operations Phase
The Operations Phase has been developed to manage ongoing well integrity during the
operational life-cycle. It has been developed to demonstrate compliance with current
legislation and the IM Standard and to provide an auditable system.
A generic methodology to manage the wells during the operational phase is outlined
below:
All wells are designed and installed in conformance with BP Global Drilling and Well
Operations Policy and shall be handed over from drilling to production with a
completed handover package
Once the well has been handed over from Drilling, the Wells Services Manager is the
Engineering Authority with accountability to ensure that processes and systems are in
place for the management of well integrity
A well integrity focal point is designated for each BP-operated field. Usually this is the
Well Operations Engineer (WOE), who is hereafter referred to as an I.M. practitioner.
Specific responsibilities are shown in the RACI charts in Addenda 3 and 4
Production start-up and operating procedures shall be developed and kept updated as
required (responsibility as per RACI chart)

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Well Operations Integrity Management Strategy NSSPU-IMS-003
The Well Services Group maintains procedures relating to the management of well
integrity. The generic well integrity operational guidelines are embedded within the
Well Services Operational Guidelines (WSOG). These are complimented by Well
Operations Procedures which are specific to each asset
Production operations personnel are responsible for the monitoring and recording of
wellhead/annulus pressures and for reporting any anomalies to the WOE (Well
Operations Engineer)
The onshore well operations engineer shall initiate diagnostic integrity work,
as required
Maximum Allowable Annulus Surface Pressure (MAASP) and Maximum Operating
Pressure (MOP) limits have been established for all wells
A well experiencing sustained casing pressure above the specified MOP shall be risk
assessed and solutions sought to correct the problem. Should continued production
of the well be justified, dispensations shall be raised by the WOE and approved by the
SPU Wells TA, with a set period for future review and renewal which shall require
SPU Wells EA approval
A field-by-field and well-by-well review is held on a regular basis and reported by the
Well Integrity engineer
IM training will be administered on a regular basis to all appropriate personnel who
can influence well integrity
Management oversight and accountability is provided by review of all wells with
anomalies before allowing continued operation. Dispensations from policy may be
issued if applicable using the approved dispensation process
An audit function is in place to provide assurance. Well integrity reviews should be
carried out regularly with the process being audited by the EA


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NSSPU-IMS-003 Well Operations Integrity Management Strategy
3 Organisation
3.1 Ownership
Ownership of the wells, through the various life cycle stages, may transfer to and from
differing disciplines depending on the work required, as shown in Figure 1. Drilling and
Completions initially hand over the well to production operations, with a complete hand
over package of documentation, with the operating envelope of the well set by the
casing, tubing and completion design. Production operations are responsible for the day
to day monitoring of well integrity activities whilst the well is on production.
Well services provide the technical discipline expertise to carry out well intervention,
repair and maintenance activities. Because of these cross functional activities, the asset
is required to identify ownership of the well during these stages and clearly describe the
responsibility areas during operations.
Drilling
Drilling
Stimulation
Stimulation
Operate & Maintain
Operate & Maintain
Repair
Repair
PxA
PxA
Handover
between
Drilling/Wells and
Operations
Trees and
Wellhead
SCSSV, ASV
Barriers
Training
Competency
Dispensations
Reporting
Casing Tubing
Annuli
Hookup
Hookup
Handover Handover Handover Handover
Drilling
Drilling
Stimulation
Stimulation
Operate & Maintain
Operate & Maintain
Repair
Repair
PxA
PxA
Handover
between
Drilling/Wells and
Operations
Trees and
Wellhead
SCSSV, ASV
Barriers
Training
Competency
Dispensations
Reporting
Casing Tubing
Annuli
Hookup
Hookup
Handover Handover Handover Handover

Figure 1 Life-cycle Responsibility
The SPU EA personally approved the appointment of both the Well Construction EA and
Well Services EA, this has been officially documented and recorded in iCan.
The Engineering Authority (EA) for well services has been assigned and is identified as
the Well Services Manager.
The SPU Wells Technical Authority (TA) has been duly appointed and has likewise been
documented and recorded in iCan.
For Norway and Wytch Farm, asset TAs have been identified and will be assessed and
appointed.
Each operational unit shall have in place a RACI chart outlining responsibilities for well
integrity tasks as shown in the example Addenda 2 and 3.

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Well Operations Integrity Management Strategy NSSPU-IMS-003
3.2 Technical Hierarchy Model
An organisational model for management of operational well integrity is illustrated in
Addendum 1. It should be noted that there are differing responsibility levels between
Norway and North Sea SPU Operations, as denoted by the dotted bold line.
The well operations engineer (IM Practitioner) is the focal point for all initial integrity
issues with regard to well operations being carried out in his/her assigned asset.
In Norwegian sector the responsibility is with the Production Operations team.
He/she has overall responsibility for ensuring that all activities are undertaken safely on
behalf of the asset. Any anomalies related to well integrity are discussed with the Wells
integrity engineer and are reported upwards to the SPU Wells Technical Authority.
The Asset TAs in Norway and Wytch Farm will consult with the SPU Wells TA on
integrity matters.
3.3 Roles and Responsibilities
An IM Standard Awareness Programme has been developed and implemented across
Operating Business, Major Projects and contractors, which covers all personnel with
involvement in integrity management. It is based on a three-phase approach:
IM e-learning module (pre-read)
IM Standard awareness course
IM Standard self-assessment based on Addendum 1 of the Integrity Management
Standard: Implementation in E&P document (post-course)
A register of everyone who attends the course has been produced and forms part of
competency profiles.
3.3.1 Engineering Authority (EA) Well Services
The Wells EA provides verification to the SPU EA that the Engineering Expectations
of the IM Standard are being met by the Well Services Team and are fully auditable.
The principal roles of the Wells EA include:
Ensures that there is a system in place that identifies and provides the required level
of engineering competence to cover the required well service disciplines for the SPU
Demonstrates that the Well Services team are meeting all applicable requirements of
the IM Standard or have a plan to address any deficiencies
Approves the selection and application of Site Technical Practices (STPs). STPs shall
be consistent with the relevant Engineering Technical Practices (ETPs) unless
approved by the appropriate EA
Establishes, maintains and approves a control procedure for the STPs. This procedure
shall specify the delegation of accountabilities from the EAs, the processes governing
the approval of variations from STPs and the criteria under which variations from these
STPs may be approved

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NSSPU-IMS-003 Well Operations Integrity Management Strategy
Identifies all Well Services posts in the SPU for which the competencies of the post-
holder must meet specific levels to ensure the effective implementation of the
IM Standard
Reviews (with SCM support) the role and responsibility of the major well engineering
contractors and confirms implementation of a competency assurance process
3.3.2 SPU Wells Technical Authority (TA) Well Integrity
The SPU Wells TA was appointed by the Wells EA and is accountable to the Wells EA
for execution of the TA role irrespective of their line reporting relationship. Certain assets
may have assigned TAs, where applicable, their role in relation to the SPU TA is defined.
The SPU Wells TA is an expert within the various disciplines and is the primary source of
technical advice to the Well Services EA. The principal roles of the TA include:
Advise the EA and asset on issues relating to well integrity
Advise on well operations equipment, maintenance and inspection frequencies and
techniques
Review and be consulted in related Management of Change efforts
Advise on the use of appropriate standards, practices and design guidelines
Serve as a principal resource to the Well Services EA for the development of STPs
Advise the Asset and Wells EA with respect to exceptions to STPs
Evaluate requests for exceptions to the STPs/Industry Standards
Actively participate in networks/communities of interest, maintaining a strong
awareness of relevant learning and technical advances
Serve as a focal point for the Wells community in the area of well integrity
Ensure that the performance standards are being met and kept up to date
Act as owner of the Wells IM Strategy
3.3.3 Wells Asset Technical Authority (TA) Well Integrity
Wells Asset TAs are engineers with specific discipline expertise appointed by the Wells
EA. The primary role of the Wells Asset TA is to act as the technical integrity advisor
within their designated activity by ensuring the safe and consistent application of
Company and regulatory codes and standards and good engineering practices.
The Wells Asset TA and Wells SPU TAs are a primary source of technical advice to the
Wells EA within the SPU. The Wells Asset TA, Wells SPU TA and the Wells EA within an
SPU should develop a close working relationship, with clear mutually agreed roles and
responsibilities.
Each Wells Asset Technical Authority shall:
Advise the Wells Asset TA, Wells and SPU staff on issues relating to technical
integrity
Be involved/consulted in MoC efforts that relate to their area of engineering expertise

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Well Operations Integrity Management Strategy NSSPU-IMS-003
Advise on the use of appropriate standards, practices and design guidelines
Advise the asset staff and the Wells SPU TA and Wells EA with respect to exceptions
to the SPU STPs
Technically evaluate requests for exceptions to the STPs/industry standards as
requested and provide a recommendation to the Wells EA
Actively participate in BP technical networks/communities of interest, maintaining a
strong awareness of technical learnings, advances within their area of speciality, etc
Advise on maintenance and inspection frequencies and techniques within their
engineering speciality where appropriate
Serve as a technical focal point for engineers within the asset in their area of
engineering speciality
3.3.4 Well Integrity Engineer
The role of the Well Integrity Engineer is to lead well integrity, provide assurance and
support to the North Sea Strategic Performance Unit, to ensure the integrity of the BP
operated and non operated well stock. The integrity engineer is directly accountable to
the SPU Wells Technical Authority.
Investigating any well integrity anomalies, developing contingency plans, monitoring
repair and maintenance performance and recommending improvements to materials
and operating practices. This may include operational support to restore integrity
Routine review and maintenance of summary records for all wells to ensure integrity
standards are being maintained
Preparation of reports summarizing integrity status and recommendations on any
actions required
Provision of general well service technical and operational support as required
Application and development of technology and best practices in Well Integrity
Management
Transfer of best practice by use of internal and external networks
4 Risk Management
4.1 General
Risk management is an integral part of the integrity management process.
Specific account of risk management is addressed in the following areas:
Basis of design
Inherent safety features as part of design
Formal safety assessments carried out
Quantitative risk assessments

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NSSPU-IMS-003 Well Operations Integrity Management Strategy
SPU S&OI risk matrix
HAZOP development and revalidation process
SIL assessments
Selection and management of the safety critical elements
Development and implementation of performance standards
Development and implementation of the integrity programmes
Compliance with STPs
Performance management process
Learning and assurance process
Hazard Identifications (HAZIDs) and HAZOPs for each asset identify the major hazards
applicable to the integrity of wells during operations. These contain a detailed
description of each hazard and the mitigating control measures taken to reduce the
likelihood of occurrence.
4.2 Management of Safety Critical Equipment
IMS requires the identification of SCEs. In the UK, SI 1992/2885 Offshore Installations
(Safety Case) Regulations and the associated SI 1996/913 (DCR), require the Duty Holder
to identify the potential major accident hazards appropriate to an installation.
Safety Critical Elements (SCEs) are those parts of the installation, or its plant, the failure
of which could cause or contribute substantially to a major accident or the purpose of
which is to prevent, or limit the effect of, a major accident.
Safety Critical Equipment shall be identified in Maximo/Workmate/STAR and assigned
inspection and maintenance activities to confirm ongoing fitness for purpose as defined
by the acceptance criteria/performance standards. Performance Standard(s) should be
produced for each Safety Critical Element. These compliment each element and provide
a benchmark for assessing their functionality during the operational phase. An example
of a performance standard is shown in Addendum 2.
A process has been adopted by the SPU, under UKCS-TS-019 for the identification of
Safety Critical Activities as illustrated in Figure 2.
The maintenance and testing of wells Safety Critical Equipment is defined in the relevant
RACI chart.
These campaigns are carried out and planned through Maximo/Workmate/STAR with
records produced for each asset.
The regularly scheduled well integrity review held by the well integrity engineer also
considers the results from the maintenance and testing campaigns from all assets and
tracks the results of the testing and maintenance.


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Well Operations Integrity Management Strategy NSSPU-IMS-003
START
Is the
equipment location tag
safety critical?
Is the activity
required to demonstrate
that the equipment conforms to a
specified performance
standard
Is this a
maintenance and/or
repair activity required to
restore, or ensure that the equipment
will perform in accordance with
a specified performance
standard
Yes
No
No
No
Yes
Yes
Yes
No
START
Is the
equipment location tag
safety critical?
Is the activity
required to demonstrate
that the equipment conforms to a
specified performance
standard
Is this a
maintenance and/or
repair activity required to
restore, or ensure that the equipment
will perform in accordance with
a specified performance
standard
Yes
No
No
No
Yes
Yes
Yes
No


Figure 2 Logic for Identification of Safety Critical Activities
Safety Critical Equipment will be managed within the overall integrity assurance process.
The process will provide a demonstrable, auditable system which will provide the audit
teams with the information required for verification. SMS document UKCS-TS-019
describes this process in more detail.
4.2.1 Performance Standards (PS)
The PS for each SCE should relate to its purpose and shall address the following:
The Risk Management Role
The PS should identify the risks that the SCE influences and how the SCE (and any other
related SCE) are intended to work so as to avoid, prevent, control or mitigate these risks.

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NSSPU-IMS-003 Well Operations Integrity Management Strategy
Functionality Requirements
How the SCE should perform, eg the safe operating temperature of a pressure system,
the speed of closure of a valve etc.
Availability Requirements
When the SCE should perform, eg always available, available within 10 minutes of
previous operation, etc.
Reliability Requirements
How well the SCE should perform, eg the ability of a valve to close on demand.
Survivability Requirements
How long it should continue to perform its intended duty under extreme loading
conditions.
Interaction Issues
How the SCE interacts with other SCE.
Performance Standards should set out the acceptable level of performance. They should
be quantifiable, where possible, and measurable by implementation of the assurance
process. They should also be written in terms that are readily understood by the
Technical and Performing Authorities.
These routines are uniquely identified and the records stored within the Maximo and
STAR (Foinaven) systems in the UK and the Workmate system in Norway.
4.3 Management of Non-safety Critical Equipment
Although the primary focus and rigour is on Safety Critical Equipment, as their failure
may result in a major incident, the Non-Safety Critical Equipment should also have risk
management programmes associated with them. This should include the relevant
maintenance, inspection, testing and operations plans as required by the IM Standard.


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Well Operations Integrity Management Strategy NSSPU-IMS-003
5 Integrity Management Process
The Integrity Management Process, see Figure 3, has been developed to demonstrate,
in an auditable manner, the way in which the integrity of wells is managed.
The process includes the following key activities for Xmas Trees and Wellheads,
ASVs and DHSVs, Pressure Control Equipment (PCE) and Tubing and Casing:
Develop management scheme
Define inspection/maintenance routines
Schedule inspection/maintenance routines
Implement inspection/maintenance routines
Implement remedial and corrective repairs
Collate inspection/maintenance information
Perform technical assessment
Retain accurate records of all regulatory tests
Recommend changes as required
Enact changes
This aligns with The Way We Work which exists to:
Create clarity of accountability and the role of organisational units
Drive simplicity in end to end business processes and systems and how we apply
governance across the SPU
Drive out waste, increase efficiency and focus on continuous improvement in
managing the business
In the Operations Division, each asset shall have a Well Operations Engineer assigned
from the Well Services team. The WOE will be the first point of contact for integrity
issues within the asset. They shall be responsible for the management of the annual
maintenance and testing campaigns for the wells under their stewardship.
In Norway there are assigned engineers within the Production Operations team that are
responsible for integrity issues within the asset.
In Wytch Farm a Well Operations Engineer assigned will be the first point of contact for
integrity issues within the asset. They shall be responsible for the management of the
annual maintenance and testing campaigns for the wells under their stewardship.
In SNS Well Operations Engineers assigned will be the first point of contact for integrity
issues within the asset. They shall be responsible for the management of the annual
maintenance and testing campaigns for the wells under their stewardship.
Written programmes shall be produced to carry out all maintenance and testing on a
campaign basis. These campaigns are called up and recorded through Maximo, STAR
and Workmate.
The Integrity Management Process applied to Well Services is based on a continuous
plan/do/measure/learn model as shown in Figure 3.

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Figure 3 Integrity Management Process
This process approach allows a set of common activities to be continuously applied
through the life of the wells, across the fields in the SPU. The process and the activities
are also applied to each part of the facility (eg pipelines, structures, pressure equipment,
etc) while allowing the unique contribution of competencies from selected service
providers and their information or data sources.

16 November 2008 Issue 1
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Well Operations Integrity Management Strategy NSSPU-IMS-003
6 Management of Change
It is a mandatory requirement within the Integrity Management Standard:
Implementation in E&P document that any change with possible business and/or
integrity management implications does not take place without a systematic process
being followed to examine the impact and manage the risks. This Management of
Change (MOC) expectation is covered in more detail in Element 7 of the above
document and is delivered in the NSSPU by the processes detailed within the North Sea
Safety Management System (SMS). By exception, some sites use site-specific
management of change procedures and systems which are aligned to the requirements
of the SMS.
All potential changes are required to go through the procedure detailed in Management
of Change (UKCS-CHM-001). This is the initial filter for all changes and defines whether
the change should take place and, if so, by what method its impact should be assessed.
The procedure allows for the selection of one of three sub-processes to control the
change: Technical, Administrative or Organisational.
Most plant and equipment changes (eg installation of Lock out of TRDHSV and
installation of an Insert Valves, change in Tree valve trim type) will go through this sub-
process and it closely follows the basic CVP gated process. This process also considers
the wider impact on, for example, documentation.
Replacing an individual or changing the entire makeup of a team can affect the way the
operation is run. A specific sub-process for this type of change exists in the system and
is detailed in Organisational Change Management (UKCS-CHM-004).
Where the life of a field is to be extended, the MOC process should be used to consider
well integrity issues.
Any changes to legislative regimes, minor modifications, PSCM change or other change
types that do not conform to the above sub-processes should be routed this way.
In many cases there is a relevant SPU procedure that will codify the process to be
undertaken. The MOC system allows approvals and an audit trail to be captured,
eg Legislation Change Process (UKCS-CHM-003).
The NSSPU performance manages the implementation of the MOC process. Key
Performance Indicators (KPIs) are utilised to allow the NSSPU to do this. The KPIs are
discussed on a monthly basis and interventions made to ensure the level of change
activity remains at a manageable level.
Once an MOC has been raised, considerable focus is given to completing the total work
package through to business closure. Every effort will be made to close the MOC within
a reasonable timeframe, whether the change takes place or not. An MOC will not
remain in an open state if there is no intention to complete the change in the
foreseeable future.

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NSSPU-IMS-003 Well Operations Integrity Management Strategy
7 IM Documentation and Data
Underpinning the IM program is a documentation and data management system that
should store the relevant integrity information in a readily retrievable form (not archived)
by the responsible IM practitioner. The documentation systems in use within the North
Sea SPU are MAXIMO, STAR and Workmate. Business critical information is also stored
in DOCUMENTUM.
A generic Tier 2 SPU model for documentation and data in support of the IM Process for
Well Service Equipment is shown in Figure 4 below. Legislation and BP Standards are
the highest level documents, followed by the Engineering Technical Practices (ETPs)
and Site Technical Practices (STPs), the Well Operations IM Strategy and the
various routines.
This documentation has been defined as the minimum requirement under the IM
Standard to ensure the effective management of the key activities in an auditable
manner.




18 November 2008 Issue 1





























Safety Case Regulations (SCR 1992)
Lifti ng Operations and Lifting Equipment
Regulations (LOLER 1998)
Provision and Use of Work Equipment
Regulations PUWER 1998)
BP Integrity Management Standard (IMS)
Design and Construction Regulations (DCR
1996)
Prevention of Fire and Explosion and
Emergency Response Regulations (PFEER
1995)
Borehole Regulations (Wytch Farm
Norsok (D-010)
Integrity
Management
Standard
Integrity
Management
Guidance
IM Support
Safety Case
HAZID, HAZOPs
ETPs/STPs
Design Data P&IDs
Equipment Regi sters
Well Operations IM
Strategy
Requirements
Well Equipment
Design Reviews
Well Equipment
Inspection
reviews
Well Equipment
Maintenance
Program
Well Equipment
Operations
Routines
Supporting Documentation
Figure 4 Documentation and Data Support
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Well Operations Integrity Management Strategy NSSPU-IMS-003
8 Performance Management
The Wells IM Strategy shall be periodically reviewed by the SPU Wells TA to ensure that
equipment and procedures are in place and are fit for purpose. Verification of
compliance with the Strategys objectives, relevant KPIs and the performance standards
are key elements of performance management. The TA will be responsible for reporting
to the EA on the performance assessments.
8.1 KPIs
Key performance Indicators (KPIs) are utilised by Well Services to measure and report
integrity issues, including any MOC actions (refer to Paragraph 6). These KPIs are
discussed on a monthly basis and interventions made to ensure the level of change
activity remains at a manageable level.
Appropriate Well Services KPIs have been established for each type of Well Integrity
activity, which reflect the key risks to be managed.
KPIs are reviewed at appropriate intervals and acted upon by the Engineering Authority
to assure conformance with the Integrity Management Standard: Implementation in E&P
document.
From a reporting perspective these shall include:
Number of overdue wells safety critical maintenance in given month
Number of deferrals of safety critical maintenance in a given month
Number of dispensations against Drilling and Well Ops Policy in a given month (this
will eventually become dispensations from ETPs/STPs)
Xmas tree and downhole safety valve failures in a given month (failure is measured
against performance standard)
IMS competency of Well Services (EA/TA and IM Practitioners)
Number of wells with annuli issues in a given month (issues are operating above
MOP or bleeding off hydrocarbons from annulus)
At the discretion of the EA/TA, other relevant KPIs may be utilised
8.2 KPI Management
All of the above KPI measures shall be reported to the Wells TA on a monthly basis.
A formal recorded KPI review meeting shall be held to identify deficiencies in
performance and to agree and assign appropriate remedial activities on a regular basis.
8.3 Annual Integrity Statement
The Wells IM Strategy will be reviewed on an annual basis. The Wells TA will be
responsible for the review to ensure it remains appropriate in the light of each years
findings. A single page Annual Integrity Statement shall be prepared for and submitted
to the Well Services EA.

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D&C
TAs
Drilling
EA
VP
Renewal
Head of
Wells
VP
Infrastructure
Norway
Head of
Quad 204
Head of
Decom
SPU
EA
Segment
EA
HODs
Q204
EA
Eng Man
Q204
TAs
Decom
EA
ETL
Decom
TAs
Head of
SNS / WYF
SNS
TAs
SNS
EA
ETL
OCTIP
EA
Eng Man
Head of
NSI
NSI
EA
Eng Man
NSI TAs
PUL
Norway
Ops
PUL
Norway
MP
BPN
EA
MP
EAs
Eng Man
Head of
Eng /
Maint /
Subsea
Ops
EA
Eng Man
Subsea &
Pipelines
Manager
Eng
SPU TAs
Pipelines
SPU TAs

VP
Operations

Head of
HSSE
Safety
Manager
Process
Safety
TA
BPN
TAs
MP
TAs
Miller
Project
Manager
Gas Asset
Manager
OCTIP
Project
Manager
Project
Manager
IMS Accountability
Segment
TAs
Ops
Manager
NWH
Project
Manager
Wells
Services
EA
Wells
TA
Head of
Production
Eng
Pipelines
EA
Subsea
EA
Head of
Ops
(4)
Production
Manager
(8)
Wytch
Farm
EA
ETL
Wytch
Farm
TAs
OCTIP
TAs
ACE
Engs
Segment
Renewal Infrastructure / Norway Operations
Decom
EA
ETL
Decom
TAs
Subsea
SPU TAs
Head of
Devs
Projects
EA
Eng Man
Dev
TAs
Operations (4) (4) (4) (10) (24) (48)
Devs &
Major Projects
(3) (3) (3) (5) (3) (30) (47)
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Well Operations Integrity Management Strategy NSSPU-IMS-003
Addendum 2
Performance Standard Example
RAVENSPUR SOUTH RB PERFORMANCE STANDARD

SC Element: Xmas Tree Valves RB/FEP/017
Strategy: Control DWI No: DWI/FEP/017

SCOPE OF PERFORMANCE STANDARD
Xmas Tree Valves:- All components associated with the Xmas Tree and associated actuated valves that provide
topside isolation of the platform wells.

GOAL/HIGH LEVEL PERFORMANCE STANDARD
The Xmas Tree valves shall provide a facility to shut in a well in accordance with a predetermined shutdown
sequence. Xmas Tree valves shall be capable of surviving the identified hazards under which they have a required
function.

This facility specific Performance Standard is designed to meet the requirements of day to day operations
related to this SCE and allow for normal verification procedures. Additional information in the referenced
Generic Performance Standard may be required for changes/modifications, out of specification conditions,
faults/failures or if there is any uncertainty.

PERFORMANCE STANDARD DETAILS

Ref No Functionality
Associated Technical
Documents and FSA
References
RB FEP01701 Actuated Xmas Tree Valve operation shall be fail safe by
ensuring valve closure on loss of signal or control pressure.
API 6 A.
RB FEP01702 The actuated Xmas Tree Valves shall have a facility for the
operator to initiate closure locally.

RB FEP01703 Xmas Tree UMV/WV shall close automatically by any of the
following actions:
Red Shutdown
Low hydraulic pressure
Hi/Lo wellhead pressure
Area fire detection
Wellhead flexible loop
ESD and F&G Cause and
Effect.
RB FEP01704 The status of the actuated Xmas Tree isolation valves shall be
indicated in the control room.

RB FEP01705 Design and operating conditions shall be identified for all the
Xmas Tree Valves (ie upper and lower master, wing valve, NASA
and manual swab valve), including pressure ratings, fluid service
and temperatures.
Completion Design
Manual.
RB FEP01706 Valve closure should be a smooth operation and take less than
45 seconds. Closure time is defined as the time taken for the
valve to reach the fully closed position from receipt of close
signal from the facility ESD logic panel.
Based on 60 seconds
allowance for detection
and closure in the QRA.
RB FEP01707 Maximum acceptable leakage rate shall be 15scf/min. Well Services Operating
Procedures.
RB FEP01708 Materials of construction shall be erosion/corrosion resistant. API 6 A Class DD.
Performance Standard Example
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Performance Standard Example
Add 2-2 November 2008 Issue 1
Ref No Availability/Reliability
Associated Technical Documents
And FSA References
RB FEP 017/09 Actuated tree valves should remain maintained and
available during the operating life of the well.
Continuing production from the well until such time as
remedial work is completed shall be subject to
authorisation by the OIM (or delegate) after
conducting a risk assessment.
Well Services Operating Procedures
Section 9.2.
Performance and Leakage Criteria.
RB FEP 017/10 The reliability of the actuated Xmas Tree Valves to
achieve isolation to the required performance
standard shall meet or exceed 98%. Testing shall be
scheduled at 12 month intervals in order to achieve
this reliability.
API 6A
Oreda 97 Taxonomy Number
4.4.3.3.
Well Services Operating Procedures:
Section 10.3, Inspection and Testing
and Section 9.3, Inspection and
Testing.

Ref No Survivability
Associated Technical Documents
and FSA References
RB FEP 017/11 Xmas Tree Valves shall retain integrity for all foreseeable fire
and explosion events.


Interactions and Dependencies
Performance
Standards
Safety Critical Elements Interactions and Dependencies
RB FEP 006 Emergency Shutdown. Initiates valve closure.
RB HYC 010 Hydrocarbon Systems. Interface between Wells, Wellheads,
Xmas Trees and Topsides Process.
RB HYC 012 Wells, Wellheads, Xmas Trees. Interface between Wells, Wellheads,
Xmas Trees and Topsides Process.

Assumptions and Limitations
1. Examination and Testing activities carried out in accordance with the Wells Examination Scheme.



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Addendum 3
UK Sector RACI Chart


UK Sector RACI Chart
November 2008 Issue 1 Add 3-1/2
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Addendum 4
Norway Sector RACI Chart


Norway Sector RACI Chart
November 2008 Issue 1 Add 4-1/2
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