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Gulf of Mexico FBM (Flag, Bypass, Monitor) Safe Work Practice. April 2008. 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. 2. FBM (Flag, Bypass, Monitor).

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fbm flag bypass monitor
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
      • 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)
  • 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/safesystems-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://laf-ctnau.chevrontexaco.com/manuals_gom/compliance/safesystems-regulatoryguidance.htm

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FBM (Flag, Bypass, Monitor)

Variances

  • 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://nor-ctnau.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:

  • 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 Works326 Camp StreetNew Orleans, LA 70130Phone (504) 525-2128Fax (504) 525-2157E-mail edsmiths@bellsouth.netWeb: www.edsmiths.com
  • The above vendor is familiar with the specs of Chevron’s GOM standard bypass tags.

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