Simultaneous Operations (SIMOPS)

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GoM Region Simultaneous Operations (SIMOPS) Safe Work Practice (SWP)

GoM Region Simultaneous Operations (SIMOPS) Safe Work Practice (SWP) Document Number: CD # UPS-US-SW-GOM-HSE-DOCUPS-US-SW-GOM-HSE-DOC-00678-2 00678-2 Document Authority:

GoM Director Ops and OMS

Document Custodian: GoM CoW Authority

Scope:

GoM H&S

Doc Admin:

GoM H&S Document Management Administrator

Issue Date:

06/12/08

Issuing Dept:

GoM H&S

Revision Date:

10/15/12

Control Tier:

2 – GoM H&S

Next Review Date:

03/01/15

OMS Element:

3.1 Risk Assessment and Management

1

Purpose/Scope

This Safe Work Practice (SWP) details the prerequisites and guidelines for the planning and execution of Simultaneous Operations (SIMOPS) to ensure the safety of personnel and protection of equipment and the environment. SIMOPS shall be defined as conducting independent operations in which the events of any one operation may impact the safety of personnel or equipment or the environment of another operation. Typically this involves production operations, drilling operations, and project execution operations, but may include any incidence where concurrent operations create risk. The SIMOPS prerequisites and guidelines detailed below apply to all operations in the GoM. This includes but is not l imited to: topsides, subsea, drilling, completion, well work, construction, marine, and pipeline or production activities. This includes activities not only onboard a producing facility but any simultaneous operations that occur field- or lease-wide.

2

Key Responsibilities

Proper coordination, communication and control are critical to the safe conduct of SIMOPS.

3

General Requirements

It is the intent of these guidelines to establish procedures for planning and coordination and outline rules to ensure that SIMOPS are conducted without incident.

3.1

Field SIMOPS Plan

Each field in the GoM shall have an approved field SIMOPS plan. A "field" is defined as any BP-operated developing or producing operation. SIMOPS plans may be required for operations outside of a field where SIMOPS risks exist between concurrent operations. This document should be kept evergreen and shall include: • •

• •

Field description description or project area description (including all fixed obstructions, infrastructure, and bathymetry) A field SIMOPS matrix (see Appendix B in this chapter for definitions of some example areas this should cover) that includes pre-risk assessed activities (see Appendix C in this chapter for an example matrix) Organization and Roles and Responsibilities Daily communications communications process specifying time and participants; participants; the the daily written report requirements and distribution must also be defined

Control Tier: 2-GoM H&S Revision Date: 06/15/12 Document Number: UPS-US-SW-GoM-HSE-DOC-00678-2 UPS-US-SW-GoM-HSE-DOC-00678-2 Print Date: 11/30/2012 PAPER COPIES ARE UNCONTROLLED. UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING.


•

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Key contact information

The plan shall include or reference existing procedures for: • Description of emergencies and All Stop Criteria •

Emergency Response and Incident Notification Procedure

•

Identification of Health, Safety, Security and Environment (HSSE) plan. If a contractor plan is being used, a bridging document must exist that reconcil es the BP and contractor GoM HSE policies. Identification of Control of Work processes, including MOCs for change-out of key personnel

•

The plan should consider additional resources that may be required based on field activity complexity, such as a dedicated SIMOPS coordinator. The field SIMOPS plan shall be in compliance with the BSEE, Coast Guard, BSEE approved Deep Water Operations Plan (DWOP) and class regulations. Any deviation from or changes to an approved SIMOPS plan requires Management of Change with appropriate Line and Technical Authority sign-off. This should include the SIMOPS plan signature authority and should be communicated and understood by all affected parties (see Section 4.4.2). Everyone has the duty to stop the job at any time the SIMOPS plan is not, or cannot be foll owed, or at any time the SIMOPS plan is not clear. The appropriate Vice President or Area Operations Manager is accountable for ensuring this field SIMOPS plan is kept up to date and is the highest level of sign-off. This should be a controlled document stored in the appropriate document management database.

3.2

Adding an Activity to the Field SIMOPS Plan

For each new activity which involves field SIMOPS the following documents are required: • •

Work plan/pack and detailed procedure Risk assessment of that procedure, including risk assessment of SIMOPS

•

A reference document that addresses the requirements outlined in Section 3.1 above with particular emphasis on roles and accountabilities

3.3

Development of Field SIMOPS Plan

Roles

Responsibilities

Vice President or Area Operations Manager

• •

Ensures that the field has a SIMOPS Plan Final level of approval for the field SIMOPS plan

Operations Support Lead or Equivalent

•

Accountable for additional activity approval

•

Field SIMOPS plan preparation

Offshore Installation Manager

•

Accountable for field SIMOPS plan content

Project Manager

•

Accountable for their project's additional activity SIMOPS requirements (per Section 3.2) to supplement the field SIMOPS plan

•

Act as integrator, working with the Activity Person in Charge (see Section 3.4) to ensure planned activities are aligned with the field SIMOPS plan in advance Ensure planned field activities are included in the Integrated Field Planning (IFP) process

•

Control Tier: 2-GoM H&S Revision Date: 06/15/12 Document Number: UPS-US-SW-GoM-HSE-DOC-00678-2 Print Date: 11/30/2012 PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING.


3.4

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Execution of SIMOPS Plan

Each field shall appoint a field SIMOPS team. The field SIMOPS team shall include at a minimum the following individual roles and responsibilities

Roles

Responsibilities

Vice President or Area Operations Manager

•

Ensures field SIMOPS plan is followed and is working

Operations Support Lead or Equivalent

•

Accountable for allocating adequate resources to support the field SIMOPS plan

OIM/Field Person-InCharge (FPIC)

The Field Person-in-Charge (FPIC) is the BP Offshore Installation Manager (OIM) unless otherwise stated. This individual is accountable for execution of the field SIMOPS plan and will have complete control to determine which operation or phase of work has precedence at any given time. The FPIC shall communicate daily with the Activity Person(s)-in-Charge (APIC) with respect to field SIMOPS activity. The FPIC or designee shall communicate with each Vessel Person(s)-in-Charge (VPIC) upon entry and departure from the particular field • •

Accountable for execution of the field SIMOPS plan Ensures that all key stakeholders (rig, vessel and facilities) are briefed and engaged, including contractors. Must have broad communications across the crews and shifts

•

Monitor daily field SIMOPS activity

• •

Chair daily field SIMOPS review(s) (daily call) Evaluate the risk of planned simultaneous operations and ensure mitigation plans are in place

Project Manager

•

Facilitate the briefing and engagement of key stakeholders, including contractors, and report back to the OIM for approval that engagement has been adequate

Activity Person-in-Charge

The individual accountable for executing a specific defined activity. The APIC shall communicate with the FPIC with respect to field SIMOPS activity. When a marine vessel/unit is a component of the activity, the APIC shall also be accountable for vessel coordination. The APIC shall communicate with the respective VPIC with respect to executing the marine activity. Examples of potential APICs are a Operations Support Lead or Equivalent, Well Site Leader or BP Representative on a vessel

(APIC)

When a single vessel is performing the activity, the APIC may assume the additional accountabilities of the VPIC. • Monitor daily SIMOPS activity •

Facilitate daily activity SIMOPS review(s)

• •

Attend daily field SIMOPS review(s) Ensure that risks associated with the planned operations are understood and communicated to the FPIC Accountable for executing a specific defined activity. When a marine vessel/unit is a component of the activity, the APIC shall also be accountable for vessel coordination

•

Vessel Person-in-Charge (VPIC)

The individual aboard the vessel accountable for executing that specific vessel's activity under the direction of the APIC. The VPIC shall



Roles

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Responsibilities communicate with the APIC with respect to activity SIMOPS. The VPIC shall communicate with the FPIC prior to entry, upon entry and upon departure from the particular field. The VPIC shall also be accountable for monitoring onboard vessel SIMOPS and identifying and reporting any SIMOPS activity that may impact the vessel's ability to perform the intended work scope (activity). In some circumstances the FPIC and APIC can be the same person; and the APIC and VPIC can be the same person. Examples of potential VPICs are a Wel l Site Leader, BP Representative on a vessel, MODU OIM, Captain, Mate or Dynamic Position Operator • Monitor daily vessel SIMOPS activity •

Facilitate daily vessel SIMOPS review(s)

• •

Attend daily activity SIMOPS review(s) Attend daily field SIMOPS review(s) - upon request

•

Execute specific vessel activity under the direction of the APIC

Officer-in-Charge

The Officer in Charge of the navigational watch is the master's representative and is primarily responsible at al l times for the safe navigation of the vessel. Examples of potential Officers in Charge are a MODU OIM, Captain, Mate or Dynamic Position Operator

Field SIMOPS Coordinator (FSC)

The FSC, if needed as an additional resource, shall provide support to the OIM and field SIMOPS team. Depending on the complexity of the activity set, the FPIC and asset management may determine a dedicated FSC is required

4

General Procedure

4.1

Identify Scope of SIMOPS Activity

Each asset must have a process in place to clearly define a detailed work scope of the field SIMOPS activity to allow for an appropriate level risk assessment to be performed. The scope must be defined early enough so that the activity risk assessment can be referenced against the asset's scheduled work activities to ensure any known SIMOPS conflicts are addressed. The Integrated Field Planning (IFP) process may be utilized to satisfy the criteria and timescale for this advance notice requirement. A typical SIMOPS process flow chart is shown in Appendix D.

4.2

Risk Assessment

An appropriate level risk assessment should be conducted and should include known SIMOPS risks by referencing the published field activity schedul e. Some key SIMOPS risks would include dropped objects, vessel collision, aviation, construction (including subsea) diving, DP failure, and loss of containment of hydrocarbons. (Refer to Appendix E in this SWP for an example of a dropped objects prevention and mitigation plan checklist.) A daily risk assessment discussion should also take place as part of the 24 hour look ahead during the daily SIMOPS meeting. Additionally, a SIMOPS matrix (BP) or equivalent tool to evaluate risks shall exist for each SIMOPS plan.

4.3

Risk Mitigation

For risks identified in risk assessments, mitigation controls should be identified and put into place. Clearly defined All Stop Criteria (with defined approval authorities) should also be outlined as part of the risk mitigation process. In addition to mitigation controls resulting from risk assessments such as the Control Tier: 2-GoM H&S Revision Date: 06/15/12 Document Number: UPS-US-SW-GoM-HSE-DOC-00678-2 Print Date: 11/30/2012 PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING.


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Dropped Objects Study, the field SIMOPS plan shall include a process to mitigate risk on a daily basis. If additional risks are identified during the established, daily communications forum, mitigation controls must be executed before the activity can commence or continue. Identification of these mitigation controls may require a separate discussion outside o f the daily communication forum.

4.4

Communication/Training of Field SIMOPS Plan and Activity Specific Information

No activity should take place pri or to approval of the SIMOPS plan and appropriate communication and training. The field SIMOPS plan shall be reviewed with all project manager(s), the Operations Support Lead or Equivalent and the appropriate APICs and FPICs prior to execution of any SIMOPS activities. The field SIMOPS plan shall be inclusive of any activity specific information as defined in Section 3.1. The review of the plan shall be completed as early as necessary to allow for a clear understanding of the risks and mitigation controls. If multiple shifts or crews will be engaged in this SIMOPS activity, then more than one review may be required to cover all crews/shifts.

4.4.1

Communication during Execution of SIMOPS Activity Plan

During the execution of the field SIMOPS plan for a SIMOPS activity, daily routine verbal and written communication must occur as defined in the plan. Participants should ensure all work groups clearly understand the scope of work that is forecast for the next 24 hours with an emphasis on SIMOPS risk mitigation. Ensure standing orders are in pl ace for non-routine communications and provide clear instructions as to when to notify the FPIC.

4.4.2

Changes to Work Scope

Stop the job, assess the risks, and initiate an MOC, if required, for all changes in work scope after the activity risk assessment and approved mitigation controls have been established.

4.5 Drilling, Completion, Remedial Rig Operations, or Well Maintenance near Producing Infrastructure 4.5.1

Potential Undesirable Events and Mitigation

Well control is a primary concern during these operations. If there is difficulty in maintaining well control (e.g., unexpected pressures, gas cut mud, lost circulation, etc.), joint communications shall occur with all parties (production, drilling, etc.) to determine if production operations shou ld be shut in. Well control procedures should be followed carefully.

Note:

First priority must be given to controlling the well and to the safety of the personnel on board.

The greatest well control hazard is wellbore intersection with a producing well. Prior directional planning is intended to avoid this interference. The plan should be reviewed by the appropriate individuals (Wells Manager, Wells Program Manager, etc.). Critical areas of SIMOPS are defined as areas in which explosive or ignitable mixtures are present or potentially present due to the release of flammable gases or vapors. During simultaneous operations, care shall be taken to avoid potential sources of ignition and damage to equipment in such areas. Critical areas include the wellheads, mud tanks and pumps, shale shaker, degasser, de-sander, producing wells, and all equipment for field processing of oil and gas.

4.5.2

Regulatory Requirements

In addition to the above general requirements, the BSEE has specific requirements for conducting rig operations in close proximity to production facilities and other hazards. The regulation at 30 CFR 250.406 requires the shut-in of all producible wells located in the affected well bay below the surface and at the wellhead when (1) a drilling rig or related equipment is moved on or off a platform, (2) a drilling unit is moved or skid between wells on a platform, or (3) a mobile offshore drilling



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unit (MODU) is moved within 500 feet o f a platform. You may resume production once the MODU is in place, secured, and ready to begin drilling operations. The Appendices to the Rig Move NTL No. 2004-G09 provide guidance on how to comply with 30 CFR 250.406. They describe the various types of rigs and phases of rig movement, specify when wells must be shut in, and delineate the documentation to be submitted to the appropriate BSEE Gulf of Mexico OCS Region (GOMR) District Office to obtain approval for a departure under 30 CFR 250.142. The Shallow Hazards NTL No. 2007-G01 includes requirements for moving rigs near pipelines and other seafloor hazards. This includes onsite preparation and rig move requirements.

4.5.3

BP Requirements

BP's Global Drilling and Well Operations Policy has specific requirements for conducting risk assessments prior to moving a rig onto an offshore location, conducting risk assessments for simultaneous operations and collision avoidance while drilling on multi-well locations.

4.6

Marine

SIMOPS involving marine vessels/units shall be managed consistent with the field SIMOPS plan.

4.6.1

Identify Activity

The field SIMOPS plan shall contain or reference a process for identifying and monitoring marine activity.

4.6.2

Risk Assessment (Identify and Evaluate Risks)

Collision is the primary SIMOPS marine risk. Any marine vessel/unit operating less than 500 meters from another marine vessel/unit or hazard to navigation shall be deemed a marine risk. Circumstances that may contribute to collision risk are vessel traffic density, environmental conditions (visibility, sea state, wind, and current), navigational aids status, vessel maneuvering characteristics and capabil ities, temporary measures in effect, vessel position reference systems, acoustic management, vessel defects and other special circumstances. Details on marine SIMOPS guidance can be found in Appendix G in this SWP.

4.7

Subsea Operations

Subsea operations may be conducted in the field to support any one of the following activities: construction, production, drilling, and seabed surveys. Each has a unique set of risks (e.g. col lision, dropped object) to be managed via a SIMOPS plan.

4.7.1

ROV Activities

Remotely Operated Vehicles (ROVs) may be deployed from any one of the production facilities, Mobile Offshore Drilling Units (MODUs) or in-field vessels and could be in support of production optimization (valve operation), inspection, repair, or component replacement, maintenance and underwater construction. Typically this will be carried out at seabed facilities, risers, pipelines, dynamic umbilicals, moorings, floating hulls and jackets.

4.7.2

Diving Activities

Diving activities typically are required only for critical maintenance and inspection of near-surface facilities such as jacket structures, sea chest valves, and riser porches. In addition to compliance with the field SIMOPS plan, to manage risk, diving operations will be performed in strict compliance with BP GoM Diving Procedures.

4.7.3

Underwater Construction Activities

This includes installation and recovery of risers, manifolds, pipelines, trees, flow line jumpers, umbilicals and associated sub-structures. This may be performed from and with a range of facilities and techniques. Control Tier: 2-GoM H&S Revision Date: 06/15/12 Document Number: UPS-US-SW-GoM-HSE-DOC-00678-2 Print Date: 11/30/2012 PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING.


4.7.4

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Survey Activities

Surveys may be performed at the seabed typically by a number of vessel surface supported techniques, such as seismic, core sampling, route co rridor surveys and metrology. In addition to ROVs, there are circumstances where non-surface connected autonomous ROVs may be deployed to carry out such functions.



5

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Appendices, Key Documents, Tools, References



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Appendix A:

SIMOPS Acronyms List Ac ro ny m AOM APIC BOP CDP D&C DP DWOP FPIC FSC HAZID HAZOP HSSE IFP JSEA/RA MASP MODU OIM OM PIC PM POB PTW ROV RP SCR SCSSV SIMOPS SWP TBD USCG VMS VPIC VRP

Defi ni ti on Area Operations Manager Activity Person In Charge Blow Out Preventer Company Designated Person Drilling and Completions Dynamic Positioning BSEE-approved Deepwater Operations Plan Field Person In Charge Field SIMOPS Coordinator Hazard Identification Hazard and Operability Study Health, Safety, Security, Environment Integrated Field Planning Job Safety and Environmental Analysis/Risk Assessment Maximum Anticipated Surface Pressure Mobile Offshore Drilling Unit Offshore Installation Manager Operations Manager Person in Charge Project Manager Personnel on Board Permit to Work Remotely Operated Vehicle Recommended Practice Steel Catenary Riser Surface Controlled Subsurface Safety Valve Simultaneous Operations Safe Work Practice To Be Determined United States Coast Guard Vessel Management System Vessel Person In Charge Vessel Response Plan (Coast Guard-related)



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Appendix B:

Typical SIMOPS Activity Definitions

Ac ti vi ty

Defi ni ti on

Boat Operations

Boat alongside Platform operations include offloading and back loading of cargo or bulk material from workboat.

BOP Lifting/Handling

Movement of BOP(s), BOP equipment over well slots, hydrocarbon piping, flexible flowlines and hoses.

Bulk Methanol/Diesel Transfer

Operations that include moving these flammable fluids through a hose.

Coiled Tubing Operations

Any entry into a well with coiled tubing.

Coiled Tubing (through rot ary)

Work done as part of the drill ing/completion or workover operation (from Rig Floor).

Completion Operations

Workover rig and drilling rig activities.

Confined Space Entry

Personnel working in confined spaces where insufficient oxygen, toxic or combustible gases may be present. Any space enclosed or partially enclosed area, either above or below deck with limited access.

Construction Operations

Equipment installation, removal or modification, repairs to processing systems, pipelines or the platform structure; and crane lifts considered as “heavy lifts” per BSEE or the Crane Operation Maintenance Program or any equipment or materials that could penetrate a deck plate if dropped while over wells and production equipment.

Cold Construction Operations

Any cold work or construction/repair activities with contract crews. Installation of equipment not requiring opening of vessels or welding, etc.

Excess Casing Pressure (Operations)

Pressure on A or B annulus in excess of 20% of design pressure.

Derrick Barge (Lifting)

Time period when barge moves to a position where a decision is made to shut down operations and/or begins to make lifts toward the platform, until lift is set and l ifting equipment is away from the platform. Period could start when the barge approaches the pl atform if there is some other need to apply restrictions, such as excessive flare radiation.

Diving

Diving to inspect or do maintenance whether from the facility or another vessel. Non-ROV.

Drilling (unknow n area)

Drilling in unfamiliar areas where you have no past experience in formation, pressures or hole trends.

Drilling in Reservoir

Drilling in known area. Drilling in hole section with known/expected hydrocarbons.

Drilling Riserless

Drilling operations conducted without a riser installed between the wellhead and the surface facility.



Ac ti vi ty

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Defi ni ti on

Explosives above Mudline

Electro-explosive devices (detonators) in wireline operations; perforators, pipe cutters, severing tools and string shot (back-off).

Fire and Gas / ESD Inoperable

Fire and gas system and/or Emergency Shut Down (ESD) inoperable or placed out of service.

Flaring

Depressurization or venting of process vessel or compressors via flare system.

Heavy Lifts (Platform, Crane) Over L ive Production Equipment

Heavy lifts over production equipment includes Platform cranes or from a barge/workboat. Platform crane lifts which exceed 75% of rated load limit, at a given angle, are considered heavy lifts. Heavy lifts by platform cranes require that wells, pressurized line s, and production facilities located in the path of heavy lifts be shut-in if not protected by solid steel decking.

Hot Work (Outside Designated Areas)

Hot work is defined as any activity, which generates a spark, flame or other ignition source under normal conditions. Welding in any location of the platform other than the designated safe welding area. Most likely includes major/minor construction projects and i ncludes safety work plans with OIM approval.

Hull Internal Inspection

Entry in hull below water-tight doors.

Open Hydrocarbon Systems

Open vessels, piping open to atmosphere prior to positive isolation and purging.

Over sid e Work

Work outside handrails, over open area or water. Work within green tagged scaffolding is NOT considered over side work.

Painting/Coating

Painting and coating at offshore location and discharge regulations also apply.

Pigging (Export Lines)

Work associated with loading, running and retrieving a pig out of an export pipeline.

Pipeline Operations

Any and all activity related to pipeline operations, with operations including all pipelines in the area, BP operated or third party operated. The pipeline includes risers, SCRs, PLETS, Wye Sleds, Subsea Tie-ins, Launchers, Receivers and other pipeline appurtenances for the transportation of oil, gas and products.

Pressure Testing (BOP, Casing, etc.)

Pressure testing during drilling operations i nvolving BOPs and casing. Also, involving a lubricator, BOPs and grease injection head, or a shooting nipple, i.e., pressure control equipment during any wireline work.

Production Operations

Flowing of any well, except as part of a back surge.

ROV Activity

Remotely Operated Vehicle (ROV) activity in controlled area of the field.

Running Riser

Running of outer production riser or drill riser.

Securing Wells

Any time wells are shut in due to heavy lifts in the well bay or for hurricane evacuation, the SSVs, manual masters and the SCSSVs will be closed. Once the wells are shut in, the umbilicals and flowlines need to be bled down.

Skidding Drill Rig

Movement of rig or major components on the deck of the facility.

Snubbing Live Well

Snubbing Operations associated with well control or production operations. A formal detailed prognosis will be developed and



Ac ti vi ty

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Defi ni ti on outlined for each snubbing operation. Snubbing operations concerns are pollution and uncontrolled well flow.

Well Clean-Up

Unloading of Well, start up/clean up prior to directing well to normal flow path.

Well Control (Drilling)

Well control conditions and the corrective actions necessary to maintain proper well control. Any time primary well control is lost either downhole or at surface.

Well Control (producing)

Abnormal well control conditions and the corrective actions necessary to maintain well control on Producing Well.

Well Stimulation (through Rotary)

Work done as part of the drilling/completion/workover operations.

Wellbore Proximity (Collision)

Conducting drilling operations where there is potential for intersection with an existing wellbore.

Wireline (Production Operations)

Wire line electrical or slick line on producing well. Work not done as part of the drilling/completion or workover operation. (Not done from rig floor).

Wireline (Rig Operations)

Wireline electrical or slickline through rotary. Electric or slickline operations from the rig floor.

Workover Operations

A conventional or concentric workover activity when performing remedial work on any wells.



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Appendix C: Example SIMOPS Matrix (Atlantis)



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Appendix D:SIMOPS Process Flow Chart

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Appendix D:SIMOPS Process Flow Chart



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Appendix E: Dropped Objects Plan Guidance Severe damage to subsea infrastructure is a major concern due to dropped objects as well as damage due to BOP lift-off and well-to-well BOP moves. A Dropped Objects Prevention and Mitigation Plan must be developed to ensure infrastructure is protected and that there is a contingency plan in effect should there be a dropped objects incident. The Dropped Objects Prevention and Mitigation Plan typically should include: 

Actions following a dropped object incident



Preemptive production shut-in:





During special deployments and recoveries if winch or crane systems are in use



During open water works



During seabed construction activities



During BOP well-to-well move



During tie-in of wells and infrastructure



Where the system may be exposed to only one barrier between hydrocarbon production and the environment



Production equipment maintenance



Well intervention



Other activities considered risky and outside the planned activities

Emergency production shut-in using an emergency shut-in system



Dropped load during vessel-to-vessel transfer



Dropped load during a load deployment or recovery with a winch or drill pipe



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Appendix G: Marine SIMOPS Risk Management Acoustic Management Plan Guidance An acoustic frequency management plan is developed when two or more vessels in the same area are using acoustics for position referencing, ROV tracking, clump weight tracking and surveying. The plan is needed to ensure maximum vessel safety and to avoid acoustic disruptions. The Frequency Management Plan assumes there is no safe distance where acoustics will not interfere. A typical acoustic frequency management plan will list frequencies in the Medium Frequency (MF) band of 19-kHz to 36-kHz band width where a frequency separation of 500-Hz is used. A 250-Hz separation may be possible, but opens up the possibility of extensive interference. A separation of 500-Hz is, therefore, recommended. A frequency management plan produces a set of compatible channel allocations and guidelines that will allow each vessel to operate freely and without concern as to the effect their acoustic operations may have on other vessels nearby. There is no need to enable and disable channels, which improves efficiency and safety. A more extensive plan may be developed for multiple vessel and survey operations. Use of a digital acoustic system opens up to an increased number of safe channels in the MF band. Use of 28 carrier frequencies combined with 16 codes give 448 unique frequencies, i.e., 224 interrogation and 224 reply frequencies. This system has little or no affect on any tone-based acoustics, specifically High Precision Acoustic Positioning (HiPap). A seismic survey operation generates noise in the water column and may give acoustic disturbance. Any seismic activity near an area where acoustics are in use needs to be planned. DP operators, in particular, must be informed of seismic activities to ensure steps are taken during seismic or other acoustic operations near a dynamically positioned vessel.

Provide Mitigations The field SIMOPS plan shall include or reference a process to mitigate marine vessel/unit collision risk. When a Safety Zone is established around a facility, the BP 500 Meter Zone Practice also shall apply. Every vessel operating in a field shall at all times maintain a proper look-out by sight and by hearing as well as by all other available means (including radar) appropriate in the prevailing circumstances and conditions so as to make a full appraisal of the situation and of the risk of collision. The field SIMOPS team may monitor vessel traffic if deemed necessary. Vessel congestion, restricted visibility, adverse weather, or other hazardous circumstances require the control, supervision, or other management of traffic and communications, including specifying times of entry, movement, or departure from or within a field.

Note:

Nothing in this document or any field SIMOPS plan is intended to relieve any vessel, owner, operator, charterer, master, or person directing the movement of a vessel from the consequences of any neglect to comply with any other applicable law or regulation (e.g., the International Regulations for Prevention of Collisions at Sea, 1972 (72 COLREGS or the Inland Navigation Rules) or of the neglect of any precaution which may be required by the ordinary practice of seamen, or by the special circumstances of the case.

Additional Precautions 

All non-essential activity on the bridge of vessels in close proximity is not allowed.



Switching between DP station keeping modes shall be avoided in close proximity.



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BOEMRE 30 CFR Subpart 250 BP Drilling and Wells Operations Directional Survey Handbook

6

Definitions

Term

Definition

SIMOPS

Conducting independent operations in which the events of any one operation may impact the safety of personnel or equipment or the environment of another operation

Marine Activity

Any and all activity related to BP's operations and use of floating production units or vessels whether on the high seas, coastal waters, in harbors or on inland waterways, including marine terminals

Marine Vessel/Unit

A generic term covering all vessels/units engaged in marine activity. Any vessel designed for the carriage of goods, equipment or people on the high seas, coastal waters or inland waterways, for the provision of services, or any offshore facility requiring positive buoyancy

Risk Assessment

The process of estimating the likelihood that an incident will occur; estimating the magnitude of the consequential loss, including the environmental impact, and making a judgment as to the significance of the risk. The scale of the risk is a function of both likelihood and consequence. Refer to Integrity Management Standard Element 3 for further information on risk assessment methodologies

Revision Log Revision Date

Authority

Custodian

Revision Details

06/15/2012

GoM H&S Director

GoM Safety Programs Lead

Reformatted document to meet new GoM document control template standardization guidelines. Appendices included in the main document

03/01/12

GoM HSSE Director

GoM HSSE Programs Manager

Changed Asset Manager references to Area Operations Managers, Removed OPM position since all facilities now have OIMS only, Changed MMS references to BOEMRE

GoM HSSE Director


All corrections made were in Section F, including adding correct links to Appendices, deleting out-of-date references, and clarifying the titles of some of the references

GoM HSSE Director


Key requirement is for each field to have an approved field SIMOPS plan More rigor and guidance for completing a SIMOPS plan added

07/17/08

06/01/2008



02/28/06

S. Garner/ S. Tink/ R. DeLeonardis/ C. Jackson

02/01/02

S. Garner/ B. Herbert/ R. White/ S. Flynn

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Kathy Kanocz

Clarified who is in charge when drilling and operations on same facility. Added example simops matrices – Atlantis and Na Kika. Added SIMOPS – Work Task Definitions. Changed CD # from 10074 to UPS-US-SWGOM-HSE-DOC-00132-2 to conform to new numbering nomenclature inside of the new GoM HSSE doc base. Changed 3 authorities and 1 custodian.

Ray Britt

Initial issue as controlled document. Prior revision history located in hard-copy consolidated manual.


Simultaneous Operations (SIMOPS)

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