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Flag, Bypass and
Monitor Procedure
While performing services for Chevron
Exploration and Production Company it is the Contractor's responsibility
to ensure that all work is performed safely and in full compliance
all applicable rules, regulations and policies.
Contents
Frequently Asked
Questions
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Q:
What should I do with all the flagging material and other tags previously
used to Flag BYPASSED devices?
A: Properly discard them.
There are two (2) tags associated with FBM, the BYPASS
Tag used when bypassing devices for start-up, testing, and maintenance
of the safety system. When a device or component is temporarily
placed out of service (e.g. test separator), then the Temporarily
Out Of Service (TOOS) Tag is used.
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Q:
What is the definition of Temporarily Out Of Service (TOOS)?
A: A component is temporarily Out-of-Service when
it is in standby, shut-down or not in use (i.e. test separators,
intermediate pressure vessels, etc) but can easily be placed in
service. Components are NOT isolated from production facilities
as per 30 CFR 250.803(c). In this situation, Safety Devices that
have been bypassed must be flagged with temporarily out of service
tags. The Safety Device functions do not have to be monitored but
must be tested and maintained in accordance with API RP 14C.
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Q: What
are the specifications for these tags?
A: Bypass Tag
- Shape: Round
- Size: 2 ˝"
- Background Color: Bright Orange
- Lettering: White – "BYPASS"
Temporarily Out-of-Service Tag
- Shape: Rectangular
- Size: 2" X 4"
- Background Color: Yellow
- Lettering: Black – "Temporarily Out-of-Service"
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Q:
What tags did the FBM Team provide to the field?
A: The BYPASS Tag, and the Temporarily Out Of
Service Tag.
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Q: What about
the Out of Service Tag?
A: These are available and/or provided by the
field. Acceptable specifications are:
- Out-of-Service Label (for panel boards)
- Shape: Rectangular
- Size: Panel specific
- Background Color: Black
- Lettering: White – "Out-of-Service"
- Out-of-Service Label (for components / vessels)
- Black spray paint stenciling is acceptable for
out-of-service components
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Q:
What is the definition of Out Of Service (OOS)?
A: A component is Out-of-Service (OOS) when it
is not being used as part of the production process and it is properly
isolated from all other production equipment or energy sources on
the facility. Safety Devices for an out of service component must
be labeled "Out-of-Service". It is not necessary to monitor
the bypassed Safety Device function. However, the PSV on any Out-of-Service
component must be left In Service, maintained and tested.
Properly Isolated as per 30 CFR 250.803(c) (2), (3)
When wells are disconnected from producing facilities and blind
flanged, equipped with a tubing plug, or the master valves have
been locked closed, compliance is not required with the provisions
of API RP 14C or this regulation concerning the following:
(i) Automatic fail-close SSV's on wellhead assemblies, and
(ii) The PSH and PSL shut-in sensors in flowlines from wells.
When pressure or atmospheric vessels are isolated from
production facilities (e.g., inlet valve locked closed or inlet
blind-flanged) and are to remain isolated for an extended period
of time, safety device compliance with API RP 14C or this subpart
is not required.
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Q: Where do I get more
tags?
A: Ed Smith Stencil Works
326 Camp Street
New Orleans, LA 70130
Phone (504) 525-2128
Fax (504) 525-2157
E-mail edsmiths@bellsouth.net
Web:
www.edsmiths.com
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Q:
What tag should be used when bypassing the boat landing ESD block
valves for inclement weather?
A: The Bypass Tag. Even though this is not considered
testing, maintenance or start-up it is an exception as stated in
the guidance document and your MMS waiver should support the flagging
requirement with no monitoring required. When the block valve is
closed you are bypassing the function of that particular ESD station.
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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Q:
When I go to an unmanned platform, I place a BYPASS Tag on the Fog
Horn Switch and arm the timer to shut off the horn. When I leave,
I want to cancel the timer to place the horn back in service. How
can I do this without damaging the timer?
A: Response from Lenny Larre: Murphy Timers need
to be cancelled before leaving. The correct way to set the timer
is to turn it all the way to 12 hours then back off to desired time.
This action puts tension on the spring, the timer may not work properly
if this is not done. As far as it stripping the timer mechanism,
the Timer is designed to turn back, if necessary, all the way back
to zero. Please have any failed timer sent to Harvey Terminal. I’ll
send it back to Murphy for a thorough analysis.
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Q:
As an electrician, I do not like to hang metal from my belt loop.
Do I have to wear the personal BYPASS tags with the stainless steel
clip?
A: NO.
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They are your tags; you can have them in your tool bag, back
pack, etc. The process does not mandate that they be worn on belt
loops.
Q:
Can I hang more then one BYPASS tag per hook on the BYPASS board?
A: NO.
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The BYPASS board is designed so that when the BYPASS tag is
removed a ? appears to prompt you…. Where is the
tag?
Q:
Can I hang the temporarily Out Of Service Tag on the BYPASS Board?
A: NO
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Q: Does FBM replace LOTO?
A: NO.
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They are separate processes and procedures. However, on
occasion FBM may be used in conjunction with the LOTO system.
Q:
Is there a limit to the number of BYPASS Boards I can have on my
platform?
A: NO.
Keep in mind that you don’t want so many tags that you are
unable to account for them. Also the regulations require that we
bypass the minimum number of devices.
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Q:
I work on a complex of platforms connected by catwalks (bridges).
I am accustomed to using the BYPASS Board, why do I need personal
tags?
A: As per the FBM guidance in the Operations Manual,
BYPASS tags will be made available in the following two methods:
Personal BYPASS Tags – These tags should be accounted
for at the end of each day.
BYPASS Boards – Located at each facility in the main
office, gaugers shack or at the panels, whichever is deemed most
effective by the workgroup.
There is no requirement for you to hang the personal tags on
your person, you can have them in your tool bag, back pack, etc.
If you never use your personal tags then you account for them at
all times, perhaps they are kept in your tool bag. In the event
you have to go out into the field to check on a satellite well,
you would have your personal tags with you to apply prior to
bypassing a safety device. Experience has shown that if you do not
have them with you, you are tempted to bypass without flagging and
are likely to forget the safety device in bypass.
Also, having personal bypass tags will enable you to flag
valves for a device you may be testing or repairing (i.e. on the
valves of a LSH that you take out of service for repair or
cleaning). Having the tags in your possession at the time of the
test or repair makes it easier to use them as a reminder that a
valve is bypassed.
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Q:
I work on a platform that has quick panels, how do I flag those?
A: Some quick panels (touch screens) show that
the device is in bypass but when you leave that particular screen
you no longer have a visual indication that something is in bypass.
For that reason, the FBM team recommended to the GOM I&E group
that any future design for new or updated safety systems must include
an external visual indicator with lamp test functionality that always
shows a device in bypass no matter what screen you move to. Some
systems may have a "bypass" dialog box that carries over
to other screen as you scroll through to remind you that something
is in bypass in the system. 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 the screen and/or the end device.
Some locations flag the touch screen that is closest to the device
bypassed, i.e. pressure transmitter and they also place a Bypass
Tag on the transmitter. You might need to place Velcro on the screen,
drill a hole, or fashion some other way to hang the bypass tag.
Plan ahead for this because the lack of having a suitable place
to hang the bypass tag may be the barrier to Flagging It First!
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Q:
I would like to use SCADA to monitor the variable (pressure, liquid
level, etc.) when the safety device is in bypass. What are the requirements
and/or guidelines?
A: The only time that bypassed safety devices
can be remotely monitored is when all conditions in this Remote
Control Section of the "Regulatory Guidance – Remote Operations
via SCADA" are met.
Remote Control
MMS NTL No. 2002-G03 and the Chevron Interpretation of
NTL No. 2002-G03 specify that you must meet at the minimum the
following requirements in order to control production facilities
remotely (this applies to all remote control including hurricane
evacuations).
- You must request permission in writing and receive approval
to remotely control the facility from your district MMS office.
You should maintain a copy of the permit request and approval at
the offshore facility, the primary offshore control room
responsible for the facility and in the hurricane evacuation
control room.
- The SCADA system must be capable of monitoring all essential
operating conditions that affect the subject wells, pipelines,
and process components.
- If the primary cause of the shut-in cannot be ascertained
via the SCADA system, an on-site investigation of the remote
facility shall be conducted before any further remote control
start-ups are attempted.
- API RP 14 C devices may be bypassed using SCADA per the
following.
a. The remote operator and SCADA system ensures that the
system pressure does not exceed the MAOP/MAWP of the system's
limiting component.
b. The operator continuously monitors all essential operating
parameters.
c. Safety devices may not be bypassed for more than 30
minutes (internal timer). Additionally, the operator has to
issue a reset command at least once every five minutes during
this 30-minute cycle to keep the 30-minute reset timer active or
the bypass function will drop out. There is no limit to the
number of 30-minute attempts. However, the system has to
completely shut-in and reaches a static state before the next
30-minute attempt is initiated. See the Chevron
Interpretation of NTL No. 2002-G03 for more details.
d. PSL upsets that because a platform shut-in (PSL First Outs)
cannot be remotely bypassed. After initiating an approved reset
attempt, a PSL First Out that was received during the reset process
because the 5-minute timer was allowed to expire shall NOT
prohibit the remote operation process. If the 30-minute timer
expires with a PSL, it will prohibit the remote operation process.
If 30 minutes is not adequate to bring the system on line, a departure
(with supporting data) should be requested from the MMS to extend
the 30-minute timer. PSL devices that are not First Outs as explained
above can be bypassed. See the Chevron Interpretation of
NTL No. 2002-G03 for more details.
e. Tripped flow line and pipeline PSH devices shall prohibit
remote control of all equipment that the SAFE Chart requires to
be affected while tripped. If the PSH device(s) clears, remote
control will be permitted. Tripped PSH devices on all other
process components may be bypassed. See the Chevron
Interpretation of NTL No. 2002-G03 for more details.
f. LSH devices can be bypassed except on sump tanks/piles,
water skimmers, flare scrubbers, and stock tanks. Tripped LSH
devices on Sump tanks/piles, water skimmers, flare scrubbers,
and stock tanks shall prohibit remote control of all equipment
that the SAFE Chart requires to be effected.
g. Tripped LSL devices shall prohibit remote control for all
equipment that the SAFE Chart requires to be affected.
h. Tripped ESD/TSE/TSH devices shall prohibit remote control
for all equipment that the SAFE Chart requires to be affected.
ESD and Storm Timer commands shall not be affected by the
position of the local/remote switch. ESD and Storm Timer
Commands shall work in either mode.
i. Compressors and all fired components cannot be remotely
controlled unless explicit written approval from the appropriate
MMS District Supervisor is granted. You should maintain a copy
of the permit request and approval at the offshore location, any
offshore control room responsible for the facility and in the
hurricane evacuation control room.
j. A SCADA system Local/Remote button is not considered part
of the Lock Out/Tag Out process because it can be potentially
remotely overridden. Anytime work is conducted on a facility
that is remotely controlled, all equipment should be locked and
tagged out as if it were a manned location.
- All safety system devices and their associated
electronic, electrical, pneumatic, and/or hydraulic circuitry
shall be fail-safe.
- The operator of the SCADA system shall be qualified and
knowledgeable of the specific SCADA system and its related
production process systems.
- Any system capable of electronic data storage shall record
operator interventions.
And the following additional guidelines.
The remote operator must place
the device in bypass.
This can only be done as part
of a reset or startup activity.
Radio communications must be
maintained between the local and remote operator at all times.
The scan time of the
applicable SCADA system must be increased to one scan per 30
seconds, not to exceed one scan per 60 seconds.
The remote operator can only
monitor a minimum number of devices. If multiple devices are
monitored, the remote operator shall be able to view the
appropriate data on one SCADA screen.
After the bypass device has
cleared, it must be returned to service immediately after the
process has stabilized.
Other site-specific guidelines
may be required. These should be documented and maintained at
the remote control facility.
Remote Monitoring of
mechanically disabled safety devices (i.e. "pinning" a pneumatic
relay") is not allowed by NTL 2002-G03.
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Q: Can you monitor bypassed Safety Device functions from a SCADA
computer that is on the same platform as the bypass?
A: Yes. If the SCADA Computer allows the operator
to monitor all needed information, for example the level of the
vessel if a LSH is bypassed, and the operator can take action from
the computer to remove the device from bypass or shut in the process.
Basically, the SCADA computer has be able to complete function as
the primary "panel" for monitoring and controlling the
safety device. If the computer only allows the operator to see the
status of the device, not the analog information, or doesn't allow
the operator to take action if something goes wrong, I would say
no it can't be monitored
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Q: If you have a 15 minute bypass timer on individual components
of a safety system, do we have to be in the vicinity to monitor?
A: 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.When an operator is "monitoring" a bypassed Safety
Device, he or she is in effect taking the place of the Safety Device
and must be able to manually provide the same level of protection
in a timely manner to prevent an undesirable event.
Previous mindsets have described monitoring as "same platform /
same deck." However, this may not be the best position to observe
the process variable (i.e. level, pressure, etc.) Qualified
personnel of the facility shall determine the process, procedures
and number of personnel required to provide "effective monitoring"
for each Safety Device that is placed in bypass. 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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