ATTACHMENT R

OFFSHORE DECOMMISSIONING SAFETY REQUIREMENT GUIDELINE

1. INTRODUCTION
Safety issue is one of major concerns in the decommissioning activities because of the
potential higher risks than normal operation. Although various laws and regulations regarding
safety and occupational health are existed, however there is no reference or guideline which
is specifically developed for the offshore E&P facilities decommissioning. This guideline is
developed to outline minimum requirements on the Occupational Health and Safety to ensure
that adequate risk assessment is conducted and mitigation measures are established and
implemented at all stages of decommissioning activities.

2. OBJECTIVE
The objective of the guideline is to provide minimum requirement for safety implications in the
offshore decommissioning activities.

3. SCOPE OF GUIDANCE
The scopes of the guideline covers offshore decommissioning activities including well
plugging and abandonment, pipeline and subsea structures decommissioning, structural
removal, onshore dismantling and disposal.

4. INTERNATIONAL FRAMEWORK AND THAILAND LEGAL OBLIGATION

There is no international legal obligation or framework specifically identifies safety
requirement in decommissioning activities.
Existing Thailand Laws and Regulations have already covered and controlled Health & Safety
issues in E&P operation as listed:
• Working with confine space, radioactive material, scaffolding, heavy machine,
explosive material and hazardous material;
• Crane operation and diver operation;
• Fire protection;
• Safety in workplace, Personal Protection Equipment;
• Risk assessment and mitigation plan.

5. GENERAL REQUIREMENTS
5.1 Selecting decommissioning option
Concessionaires shall include human safety as one of major components in selecting
decommissioning options as required but not limited to activities stated in BEPO guideline.

5.2 Decommissioning methodology/procedure

Concessionaire shall demonstrate that all decommissioning activities are performed safely
under the safe work practices, applicable legislation requirements and industrial standards.
Concessionaire shall ensure that all risky activities are identified and their mitigation plans are
set up to properly manage all risks related to the decommissioning activities or to reduce
them to “As-Low-As-Reasonably-Practicable; ALARP” level.
Concessionaire shall also submit its “Safety Management Plan” together with the Final
Decommissioning Program.

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The Safety Management Plan shall identify all Hazards and Risks from the Decommissioning
activities and mitigation measures to minimize such hazards and risks. Major components
that should be considered in Safety Management Plan are as listed, but not limited to:

• Heavy lifting of aged structure & facilities;

• Hot work with hydrocarbon /flammable contaminated piping & equipment;
• Working with hazardous substance and contaminated equipment;
• Electrical Safety;
• Working in confined space environment;
• Working with piping /vessels under pressure & trapped pressure;
• Excavation Safety;
• Working at height and Dropped Objects from Height;
• Sub sea Pile/ Structure cutting operation, especially when explosives or diving
operation is used;
• Dismantling and disposal activities;
• Human Fatigue & Stress.

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 APPENDIX A
Assessment of Decommissioning Safety Standard Requirement (Offshore)

1. BACKGROUND AND OBJECTIVE

Safety issue is one of major concerns that has been identified from joint project framing
workshop among industries and other decommissioning stakeholders including NGO’s and
academics in May 2006.
As known that, there are potential higher risks in decommissioning activities than normal
operation. Currently, there is no specific requirement in safety regulation/ standard to protect
human safety in decommissioning process. This assessment is made to:
• Identify perspectives on safety related issues in decommissioning activities;
• Review current decommissioning safety regulation/standard;
• Set up requirement for safety implications in decommissioning process.
Scope of decommissioning activities as identified in this assessment is including well plug and
abandonment, pipeline and sub sea structures decommissioning, structural removal, onshore
dismantling and disposal.

2. STAGES IN DECOMMISSIONING PROCESS

There are fours major stages in decommissioning activities:

2.1 Planning and engineering:

Concessionaire is required to prepare a decommissioning program which identifies
the decommissioning options, evaluates the technical feasibility, assesses the
environmental and social impacts and minimize the risks to human health and safety.

2.2 Preparatory works

• Well P&A
After end of production, wells need to be plugged and abandoned. Well tubing sand
steel casing will be cut and removed. Refer to Offshore Well Plugging and
Abandonment Guideline (Attachment H).
• Pipeline Disconnection
Any Pipelines connected to the structure need to be flushed and cleaned prior to be
disconnected. Most of the pipelines are left-in-place after ensuring that they are not
obstructed other sea users and caused for marine environment pollution. Refer to
Offshore Pipelines Decommissioning Guideline (Attachment J).

2.3 Structural removal

• Topsides removal
Topsides will be cut / disconnected from jacket and piles. Depending on the size
and capacity of the crane, Topside can be removed either in small pieces or in a
single large lift.
• Severing piles
Piles and jacket legs will be cut either by cold cutting or explosion to disconnect
jacket from underground structure.
• Jacket removal

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 There are several options for jacket removal, reef-in-place by toppling, reef at
remote site, or onshore disposal. The selected option will be based on government
policy, size and lifting capacity of lifting equipment.

2.4 Onshore dismantling and disposal

• Offshore structures will be bought into onshore;
• Process components are to be removed from structures or skids. Components,
which are potentially contaminated, will require proper decontamination prior to
their disposal;
• Marine growth will be removed from jackets and sub-sea structures prior to
their disposal;
• Remaining non-contaminated steel can be cut into managing pieces for
recycling;
• Processing equipment can be reused, should they meet the requirement
described in Reuse Standard Guideline (Attachment N).

3. DECOMMISSIONING PERCEPTION
3.1 Risk comparison between installation and decommissioning processes

Installation Decommissioning

• Require lifting crane barge, labor
skills
• Clean and New Facility
• Well Engineered, well planned
procedure
• Pile Hammering through seabed
• Weight Controlled, fixed center of
Gravity (CG)
• New Structure High Integrity
• Hazardous Operation
• Jacket installation aided by gravity
• Accurate known weight
• Piles are always separate driven
• Require lifting crane barge, labor
skills
• Likely Contaminated Facility
• Potential to unexpected events at all
time
• Pile cut with Explosive, water-jet,
diamond wire
• Weight, CG change due to
modification, marine growth
• Aged structure unexpected weak
point due to fatigue or corrosion
• More hazardous operation
• Jacket removal against gravity
• Uncertainty in weight due to friction,
marine growth, over-burden on mud-
mats.
• Piles may have to be lifted with
jackets.

3.2 Hazards and risks in decommissioning activities

3.2.1 During offshore facilities decommissioning
• Installation must be isolated from sources of hydrocarbons;
• Well must be plugged, sealed and abandoned;
• Pipeline must be isolated and ultimately disconnected;
• Processing equipment shall be depressurized, freed from any liquids and
hydrocarbons.
Failure can lead to:
• Release of flammable, explosive or toxic liquids and gases;
• Personal injury from entering contaminated/ un-pressurized vessel;
• Fire incident due to lack of fire fighting capacity.

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 3.2.2 During offshore facilities removal
• Equipment needs to be dismantled and size-reduction;
• Deck and structure will be cut and removed by heavy lift operation.
Failure can lead to:
• Residues could ignite during thermal cutting or grinding;
• Exposure to harmful substance during removed (e.g. Hg, As, etc.);
• Fire incident due to lack of fixed system for fire and gas detection, alarms
and fire fighting equipment;
• Human injury on emergency case due to unavailability of escape,
evacuation and rescue;
• Risk of diver working close to potential unstable structure;
• Falling of un-integrity structure from lifting operation.
3.2.3 During offshore facilities transportation
• Structure will be sea fastened and transferred from barge to onshore
facilities.
Failure can lead to:
• Contamination of toxic substances during transportation to disposal site;
• Human injury from falling of un-integrity structure
3.2.4 During onshore dismantling and disposal
• Equipment will be cleaned and removed from the structure or skid for
recondition/ reuse/ disposal;
• Structure will be cut into pieces for disposal.
Failure can lead to:
• Residues could ignite during thermal cutting or grinding;
• Exposure to harmful substance during cleaning and disposal (e.g. Hg,
As, etc.);
• Human injury from falling of un-integrity structure from lifting operation.

4. RELATED GUIDELINES AND REGULATIONS

4.1 International Regulatory Regime
4.1.1 UK regulatory regime
SCR Offshore Installations (Safety Case) Regulations 1992
Require an Abandonment Safety Case for every offshore installation to be submitted
for HSE acceptance at least six months before decommissioning begin. Safety case
must demonstrate that:
• Management systems are adequate;
• Audit arrangement are adequate;
• Major hazards have been identified;
• Risk have been evaluated and measured designed to reduce risk to “As
Low As Reasonably Practicable”.
Content of Abandonment Safety Case for offshore installation is shown in Appendix
B.
PFEER 1995 (HSE Prevention of Fire and Explosion, and Emergency Response
Regulations)
Require duty holders to protect their personal from effects of fire and explosion and to
have effective evacuation, escape and rescue (EER) arrangements. The adequate of
such arrangement s will require assessment before decommissioning can begin.
DCR (HSE Design and Construction Regulations)
Require new designs to take into the safety of eventual decommissioning and
dismantling, ensuring that structural integrity is maintained during such operations.

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 4.1.2 USA Federal register 30 CFR 250,256
No specific requirement for safety standards in decommissioning process.
Safety issue is identified as criteria for option selection and for diving operation
(seafloor stability).
There is also a Safety and Environment Management Program (SEMP) which is
subject to voluntary implementation.

4.2 Thailand National Regime

Existing Thailand Laws and Regulations have already covered and controlled Health
& Safety issues in E&P operation as listed:
• Working with confine space, radioactive material, scaffolding, heavy
machine, explosive material and hazardous material;
• Crane operation and diver operation;
• Fire protection;
• Safety in workplace, Personal Protection Equipment;
• Risk assessment and mitigation plan.
(Noted: Reference list of Laws and Regulation is shown in Appendix C)

5. SAFETY IMPLICATION IN DECOMMISSIONING PROCESS

5.1 Selecting decommissioning option
Best Practical Environmental Option (BPEO), originally developed in the UK, is now
implemented for the selection of the best option. Major components of BPEO are:
• Technical feasibility;
• Environmental impact;
• Human safety;
• Cost;
• Public acceptability.
BPEO has already been implemented to assess option in decommissioning activities
as listed: Seabed deposit, cutting method and depth, pipeline decommissioning and
jacket disposal option (reef/onshore).
Note: Refer to Standard Tools for Selecting Decommissioning Option Guideline
(Attachment C).

5.2 Decommissioning methodology/procedure

Existing Thai’s Laws and Regulations have not fully covered, but can be adapted to
activities in decommissioning process as same as E&P operation and installation
work.
Besides of existing laws/ regulations, every company has established their own safety
procedures and standards for offshore activities following international standard and
guideline e.g. Occupational Safety and Health Administration (OSHA), International
Association of Oil and Gas Producers (OGP), American Petroleum of Institute (API)
and etc. Human safety is already taken in account as one of main concern for each
company,
Only one concern that has been raised from safety experts is risk on heavy lifting of
aged structure for offshore decommissioning work. Revision of structural analysis and
lifting procedure review is required to mitigate potential risk.

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6. RECOMMENDATION
Decommissioning can be considered as a reverse process of installation and commissioning,
and each individual company already has its own safety standard to cover those physical
activities.
There is no need for specific safety standard for decommissioning activities.
Only one specific requirement that will be in the guidelines is:

“Concessionaire shall demonstrate that all decommissioning activities are performed

safely under the safe work practices and industrial standards.
Concessionaire shall ensure that all risky activities are identified and their mitigation
plans are set up to properly manage all risks related to the decommissioning activities
or to reduce them to “As-Low-As-Reasonable-Practice; ALARP” level.
Concessionaire shall also submit its “Safety Management Plan” together with the
Final Decommissioning Program and should be updated within 6 months prior to the
actual decommissioning execution.
The Safety Management Program shall identify all Hazards and Risks from the
Decommissioning activities and mitigation measures to minimize such hazards and
risks. Major components that should be considered in Safety Management Plan are
as listed, but not limited to:

o Heavy lifting of aged structure & facilities

o Hot work with hydrocarbon * flammable contaminated piping & equipment
o Working with hazardous substance and contaminated equipment
o Electrical Safety
o Working in confined space environment
o Working with piping /vessels under pressure & trapped pressure
o Excavation Safety
o Working at height and Dropped Objects from Height
o Sub sea Pile/ Structure cutting operation, especially when explosives is used
o Dismantling and disposal activities
o Human Fatigue & Stress”

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Appendix B: Content of Decommissioning Safety Case (UK)

The Offshore Installations (Safety Case) Regulations 1992

SCHEDULE 5
Regulation 7

PARTICULARS TO BE INCLUDED IN A SAFETY CASE FOR THE ABANDONMENT OF A

FIXED INSTALLATION

1. The name and address of the operator of the installation.

2. A description, with scale diagrams, of—
(a) The main and secondary structure of the installation and its materials;
(b) Its plant;
(c) The layout and configuration of its plant;
(d) The connections made to any pipe-line or installation; and
(e) Any wells connected to the installation.
3. A scale plan of the location of the installation and of anything connected to it, and
particulars of—
(a) The meteorological and oceanographic conditions to which the installation may
foreseeably be subjected; and
(b) The properties of the sea-bed and subsoil at its location.
4. Particulars of the operations which were being carried out, including activities on and in
connection with the installation relating to each operation.
5. The maximum number of persons at work on the installation during decommissioning.
6. Particulars of the plant and arrangements for the control of the operations on a well,
including those—
(a) To control the pressure in a well;
(b) To prevent the uncontrolled release of hazardous substances; and
(c) To minimize the effects of damage to subsea equipment by drilling equipment.
7. A description of any pipe-line with the potential to cause a major accident, including—
(a) The fluid which it conveys;
(b) Its dimensions and layout;
(c) Its contained volume at declared maximum allowable operating pressure; and
(d) Any apparatus and works intended to secure safety.
8. Particulars of plant and arrangements for—
(a) The detection of the presence of toxic or flammable gas;
(b) The detection, prevention or mitigation of fires; and
(c) The protection of persons from their consequences.
9. Particulars of escape routes, embarkation points and means of evacuation to enable the
full and safe evacuation and rescue of persons to take place in an emergency.
10. Sufficient particulars to demonstrate that the proposed arrangements, methods and
procedures for—
(a) Dealing, by way of abandonment or otherwise, with any wells to which the
installation is connected;
(b) Decommissioning the installation and connected pipe-lines; and
(c) Demolishing or dismantling the installation and connected pipe-lines, take
adequate account of the design and method of construction the installation and its
plant, and reduce risks from a major accident to the lowest level that is reasonably
practicable.
Appendix C: Reference for Existing Thailand Laws and Regulations

Ministry of Interior

23 July B.E. 2519

ƒ Notification of Ministry of Interior Re: Work safety relating
to the use of machinery

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 ƒ Notification of Ministry of Interior Re: Work safety relating 30 May B.E. 2520
to the working environment (Chemical)
30 June B.E. 2525
ƒ Notification of Ministry of Interior Re: Work safety relating
to the construction with the use of scaffolding.
10 September B.E.
ƒ Notification of Ministry of Interior Re: Work safety relating
2528
to the construction zone
17 April B.E. 2530
ƒ Notification of Ministry of Interior Re: Work safety relating
to the use of cranes
22 August B.E. 2534
ƒ Notification of Ministry of Interior Re: Work safety relating
to the use of chemical
ƒ Notification of Ministry of Interior Re: Work safety relating 18 October B.E. 2534
to work sites with risk of falling from high places, or being
harm by materials either by way of spatter, fall or
collapse

Ministry of Industry

ƒ Hazardous Substances Act B.E 2535 Re: The control of 29 March B.E. 2535
hazardous substances
2 June B.E. 2542
ƒ Notification of Ministry of Industry No.2 (B.E. 2542) Re:
Reporting information regarding type, quantity, source,
usage method and storage of radioactive substances
18 November B.E. 2542
ƒ Notification of Ministry of Industry No.3 (B.E. 2542) Re:
Safety measures for the operation
17 November B.E. 2543
ƒ Regulation of Department of Industrial Works Re:
Danger indication of risk assessment and preparation of
risk management plan
ƒ Hazardous Substances Act (No.2) B.E. 2544 9 November B.E. 2544
23 August B.E. 2545
ƒ Notification of Ministry of Industry No.1 (B.E. 2545) Re:
Safety measures in the operation issued under the
Factory Act B.E. 2535
6 November B.E. 2546
ƒ Notification of Ministry of Industry Re: Safety measures
in the factory business’s operation with regard to working
environment B.E. 2546

Ministry of Labor

ƒ Ministerial Regulation Re: Determination of safety, health 27 April B.E. 2547

and working environment standards in the stuffy
workplace B.E.2547
ƒ Ministerial Regulation Re: Determination of safety, health 24 June B.E. 2547
and working environment standards of any work relating
to the ionizing radiation B.E.2547

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 8 March B.E. 2548
ƒ Ministerial Regulation Re: Determination of safety, health
and working environment standards relating to dived
work B.E.2548
16 February B.E. 2549
ƒ Ministerial Regulation Re: Determination of safety, health
and working environment standards relating to heat, light
and noise at workplace B.E.2549
ƒ Ministerial Regulation Re: Determination of safety, health 21 June B.E. 2549
and working environment standards B.E.2549

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