Operating Procedures - Preliminary Results of a Safety and Environmental Management Program (SEMP) Case Study Sponsored by the DOE and MMS

Abstract

Abstract On June30, 1994, the MMS published a Federal Register notice requesting that industry voluntarily adopt API RP 75 (SEMP). Under the SEMP program, offshore producers would be responsible for identifying potential hazards in the design, construction and operation of drilling and production platforms and developing specific approaches to reduce the occurrence of accidents. Many smaller and mid-size independent producers have raised questions over the costs and methods for implementing SEMP. The DOE and MMS determined that a carefully documented case study would answer many of the producers' questions. The results of the study would be oriented specifically to small- and mid-size companies, so independent producers would be much more willing to invest the time and resources to adapt theRP 75 procedures to their own operations. As a result, the DOE and MMS have entered into a 30-month study with Taylor Energy Company (TEC) and Paragon Engineering Services (Paragon) to develop a Safety and Environmental Management Plan (SEMP). This program is intended to demonstrate how small- to mid-size companies can effectively and inexpensively develop a SEMP in accordance with API RP 75. This paper will discuss the preliminary findings associated with the Taylor Energy Company/DOE SEMP case study. Specifically, the development of operating procedures which meet the intent and spirit of SEMP without the traditional high cost typically associated with 'engineered operations manuals' will be discuss. Introduction Section 5 of SEMP is titled 'Operating Procedures' and is written almost identically to the Operating Procedures section in API 750, Management of Process Hazards. This fact is important to understand because API 750 was developed for refineries, petrochemical operations, and major onshore processing facilities. API 750 is not directly applicable to most OCS platforms. Since the goal of this SEMP project is to develop a 'cost-effective' method for small and mid-sized independents, this paper will provide thoughts on how to achieve the 'spirit' of SEMP without incurring the paperwork burdens of a complex facility operation. Overview of Section 5- SEMP Operating Procedure Section 5.2.a requires that the written procedures include the job title and reporting relationship of the person or persons responsible for each of the facility's operating areas. This goal can be accomplished with a simple organization chart for moat small and mid-sized independents. In many cases, such a chart already exists. Section 5.2.a offers no pertinent benefit to the small independent because, in the majority of cases, only one operator (and a helper or roustabout) is responsible for an entire platform and perhaps one or more unmanned facilities as well. The small independents' organizational structure is usually very flat, unlike that of a large organization typically associated with a refinery or petrochemical complex.