Transcript Sim Ops CBT & Quiz - Chevron

Gulf of Mexico
FBM (Flag, Bypass, Monitor)
Safe Work Practice
April 2008
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FBM (Flag, Bypass, Monitor)
OE Tenets
 Tenet #3 - Ensure safety devices are in place and
functioning
 The safety system is there to protect:
People
Property
Environment
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FBM (Flag, Bypass, Monitor)
Purpose & Objectives
 This guidance is provided to ensure that all field
personnel comply with the regulations as found at
30 CFR 250.803(c) (1) and 30 CFR 250.1004 (c).
INCs issued against these regulations could result
in significant civil penalties, and if found to be a
deliberate violation, could escalate into a criminal
violation; however, of greater concern is the
potential negative ramifications of the safety and
health of our personnel.
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FBM (Flag, Bypass, Monitor)
The Regulations
 30 CFR 250.803(c)(1)
 Surface or subsurface safety devices shall not be
bypassed or blocked out of service unless they are
temporarily out of service for startup, maintenance,
or testing procedures. Only the minimum number of
safety devices shall be taken out of service.
Personnel shall monitor the bypassed or blocked-out
functions until the safety devices are placed back in
service. Any surface or subsurface safety device
which is temporarily out of service shall be flagged.
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FBM (Flag, Bypass, Monitor)
The Regulations
 30 CFR 250.1004(c)
 If the required safety equipment is rendered
ineffective or removed from service on pipelines
which are continued in operation, an equivalent
degree of safety shall be provided. The safety
equipment shall be identified by the placement of a
sign on the equipment stating that the equipment is
rendered ineffective or removed from service.
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FBM (Flag, Bypass, Monitor)
Regulatory Clarity
 Flag
 Any surface or subsurface safety device which is
temporarily out of service shall be flagged.
 Minimum Number of Devices
 You may only bypass safety devices required to
allow the start-up, testing, or maintenance task to
be performed. Although it may be convenient to use
a "Group Bypass" or to bypass extra safety devices
to prevent nuisance shut-ins, use of such group
devices would be a clear violation of bypassing more
than the minimum.
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FBM (Flag, Bypass, Monitor)
Regulatory Clarity
 Monitor & Control
 Personnel shall monitor the bypassed or blocked-out
functions until the safety devices are placed back in
service. An operator shall be in a position to monitor
the function of the bypassed device. If you detect an
abnormal condition then you must take corrective
action (close inlet valve, ESD platform, etc.) to
prevent an undesirable event.
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FBM (Flag, Bypass, Monitor)
 Chevron GOM Flag-Bypass-Monitor
System Requirements
 Personnel shall monitor the bypassed or blocked-out
functions until the safety devices are placed back in
service. An operator shall be in a position to monitor
the function of the bypassed device. If you detect an
abnormal condition then you must take corrective
action (close inlet valve, ESD platform, etc.) to
prevent an undesirable event.
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FBM (Flag, Bypass, Monitor)
Training
 All Chevron Production Safety System trained
Operations personnel are required to complete
the GOM FBM Training modules in LMS (KP) on
an annual basis and attend HES Supersessions
where FBM skills assessments will be conducted.
Regular Contract Operators shall be required to
complete these modules as soon as GIL Access is
granted and annually thereafter.
 Newly hired PSS trained Contract Operators shall
be given a hard copy of the FBM Process as soon
as practical and they shall be formally introduced
to the FBM Process by Field Management during
their first hitch on Chevron property.
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FBM (Flag, Bypass, Monitor)
Flags
 Flags shall be made available in the following 2
methods:
 PERSONAL TAGS - tags will be provided to each
qualified person
 BYPASS TAG BOARDS - Bypass board(s) will be
located at each facility in the main office, gauger
shack or at the panels, whichever is deemed most
effective by the work group.
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FBM (Flag, Bypass, Monitor)
Bypass Procedures

Flag – Bypass – Monitor – Return to Service

The following procedures shall be used when placing a
Safety Device in bypass:
 Notify all affected personnel
 Flag Safety Device to be bypassed
 Bypass Safety Device
 Monitor the bypassed or blocked-out functions
 Complete start-up, maintenance, or testing
 Return Safety Device to service
 Remove the bypass flag
 Notify all affected personnel
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FBM (Flag, Bypass, Monitor)
Secondary Flagging
 If a safety device is bypassed in such a manner that its
condition or operating mode is not clearly visible, then
a second flagging device will be installed on the front of
the associated control panel so that it is clearly visible.
(i.e. devices/isolation valve inside control panel, slave
panels, plugged relay ports, boat landing ESD, etc.)
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FBM (Flag, Bypass, Monitor)
 Examples of Devices that can be Bypassed
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
Boat landing ESD station/loop* (Special circumstances apply)

Burner Safety Low (BSL)

Combustible Gas Detectors (ASH)

Containment System

Fire Pump

H2S Detectors (OSH)

Level Safety High / Low (LSHL)

Platform ESD system

Pressure Safety High / Low (PSHL)

Pressure Safety Valves (PSV) WARNING: NEVER FOR START-UP

Pressure Vacuum Safety Valves (PVSV) WARNING: NEVER FOR START-UP

Shutdown Valves (SDV)

Smoke Detector (YSH)

Sump Pump

Surface Controlled Subsurface Safety Valves (SCSSV)

Surface Safety Valves (SSV)

Thermal Detector (TSH)

TSE System
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FBM (Flag, Bypass, Monitor)

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Example Methods of Bypassing

Electrical jumper lines

Pneumatic jumper lines

Remote SCADA system

Control panel "Bypass" / "In-Service" selector valves

Block valves under PSV

Isolation valve for the SCSSV at wellhead

SCSSV hydraulic dump valve manual override

Fusible caps on the SSV

Manual override wheels for SSVs/SDVs/BDVs

Pneumatic relay chocks

Isolation valves for LSHL

Sensing line selector valves for PSHL testing

Pinned relay

Boat landing ESD isolation valve

Three way valve on SSV /SDV / BDV (trapped pressure)

Breakers

Plugged bleed ports

Block valves on supply system (sump pump)

Electrical leads for power supply (fog horn)
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FBM (Flag, Bypass, Monitor)
Isolation Valves
 An Isolation Valve is any valve that can disable a safety
device.
 Any valve that may be closed, isolating a safety device
presents serious risks. Any such valve that must be
closed for Start-Up, Maintenance or Testing shall be
flagged with a FBM tag.
 Flagging a bypassed safety device at the Master Panel
does not preclude the installation of an additional tag on
the Isolation Valve.
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FBM (Flag, Bypass, Monitor)
Site Specific Monitoring Procedures
 Qualified personnel bypassing safety devices will be
responsible for answering the following questions:
 What is the process variable to be monitored?
 What device will be used to monitor the process variable?
 How will the process be controlled?
 At what point must I react to prevent an undesirable
event?
 Will this procedure provide the same level of protection as
the Safety Device?
 How many people are required?
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FBM (Flag, Bypass, Monitor)
Remote Monitoring of Bypassed Devices
 The only time that bypassed safety devices can be
remotely monitored is when all conditions in the
Remote Control section of the GOM Regulatory
Guidance - Remote Operations via SCADA apply.
 Consult OE Operations Manual for detailed guidance.
 http://laf-
ctnau.chevrontexaco.com/manuals_gom/compliance/safe
systems-fbm.htm - GOM Operations Manual - Compliance
Assurance - Flagging, Bypassing, and Monitoring (FBM) of
Safety Devices.
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FBM (Flag, Bypass, Monitor)
Remote Monitoring of Bypassed Devices
 Additional Guidance
 Additional remote monitoring and control guidance can be
found in the GOM Regulatory Guidance - Remote
Operations via SCADA in the Operations Manual. This
guidance was developed by GOM Electrical Engineering
and HES Subject Matter Experts and is based on NTL
G03-2002.
 GOM Regulatory Guidance - Remote Operations via
SCADA link is http://lafctnau.chevrontexaco.com/manuals_gom/compliance/
safesystems-regulatoryguidance.htm
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FBM (Flag, Bypass, Monitor)
Variances
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
There are NO exceptions to flagging a bypassed Safety Device. This
includes MMS inspections, internal company inspections and monthly
inspections.

Violation of the FBM Policy may result in a formal investigation. Results of
investigations that reveal willfull policy violation may include disciplinary
action up to and including termination of employment.

There are no variances for the tags specifications.

Applying a bypass flag is not required for self-flagging devices (i.e. Quick
Panels with external visual indicator(s) and lamp test functionality, SCADA
screens). If your electronic safety system does not give a clear, visual
indication of bypassed devices at all times, then you must apply bypass
flags to screen and/or the end device.

At non-OCS locations, reasons for variances from this flagging standard
must be documented by the appropriate area / location and approved by
their respective Operations Manager, Asset Team Leader, or equivalent.
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FBM (Flag, Bypass, Monitor)
Special Circumstances

Boat Landing ESD Stations and Loops
 It is common for locations to have a departure from the
MMS to install a block valve in the boat landing ESD
supply line. Such departures typically allow for these
valves to be closed during inclement weather ONLY. They
do not need to be attended but they must be flagged.
Block valves in the boat landing ESD supply line must be
tie-wrapped (locked) in the open position at all other
times.
 20% of all MMS issued P-103 Incs are for Boat Landing
ESD Stations bypassed in violation of the departure.
Note: This requires an MMS departure with specific
conditions that must be met.
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FBM (Flag, Bypass, Monitor)
Fog Horns
 If, and only if, conditions are clear and fog is not
anticipated, personnel may turn fog horns off on
manned structures to avoid having the fog horn
sounding @ 133db continually while personnel are on
board. A Temporary Out of Service (TOOS) tag
shall be placed on the unit any time the horn is
out of service, for any reason, whether it is a
manned or unmanned platform.
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FBM (Flag, Bypass, Monitor)
Fog Horns
 During periods of anticipated fog, since there is a
risk/exposure when the fog horn is in the “off position”
on a manned structure that fog may roll in while every
body is asleep, an attendant must activate the fog horn
before retiring for the evening. If a night crew is
present, it will be his/her responsibility to turn on the
fog horn. This addresses the monitoring requirement
and must be everyone's responsibility.
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FBM (Flag, Bypass, Monitor)
Fog Horns
 The intent of the TOOS flag is to remind all personnel
that a safety device (even though not a API RP 14C
device, but still a device there to protect people,
property, and the environment) is unable to perform its
design function.
 See GOM NavAids web site for Fog Horn Requirements,
Outage Reporting and Inspections at http://norctnau.chevrontexaco.com/navaids/
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FBM (Flag, Bypass, Monitor)
MMS Inspections
 Should the MMS arrive while a safety device(s) is
bypassed, immediately notify the MMS Representative
of all device(s) that are flagged and bypassed, why
they are bypassed, and how they are being monitored.
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FBM (Flag, Bypass, Monitor)
Tie Wraps
Tie Wraps on PSV Isolation Valves:



As per 30 CFR 250.803 (b)(1)(i): Each Stop / Block valve between a
PSV and a Pressure vessel must be locked or sealed in the open
position.
Third Party Valve Technicians shall utilize orange colored tie wraps
when sealing PSV isolation valves in the Open position.
Company or Contract Operations Employees shall utilize any
flourecent colored tie wraps, except orange, when sealing PSV
isolation valves in the Open position
Tie Wraps on other Safety Device Isolation Valves:

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The utilization of tie wraps on safety device isolation valves is a
common practice across GOM operations. Each Operations Supervisor
should evaluate, formulate and implement site specific use of tie
wraps in their own areas as they see fit.
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FBM (Flag, Bypass, Monitor)
Vendor for Tags and Boards
 Tags may be purchased from the following approved
vendor:
 Ed Smith Stencil Works
326 Camp Street
New Orleans, LA 70130
Phone (504) 525-2128
Fax (504) 525-2157
E-mail [email protected]
Web: www.edsmiths.com
 The above vendor is familiar with the specs of
Chevron’s GOM standard bypass tags.
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Questions?
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