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Procedimiento Variance
Procedimiento Variance
Procedimiento Variance
PROCEDURE
C02.01.05-04-PR01
PROCEDURE FOR VARIANCE, CHANGE
CONTROL & NON-COMPLIANCE REPORTING
December 2004
CONTENTS
Distribution List iii
Revision Status iii
List of Abbreviations iv
Glossary of Terms v
1. INTRODUCTION 1
1.1 Objectives 1
1.2 Scope 1
1.3 References 1
1.4 Records 2
2. RESPONSIBILITIES 2
3. PROCEDURE 2
3.1 Definition of Terms 2
3.2 Non-Compliance Reporting Procedure 3
3.3 Variance Procedure 4
3.3.1 Venezuelan Statutory Requirements 4
3.3.2 SVSA Policies, Standards and Procedures 6
3.3.3 Operational and Maintenance Routine and Non-routine Overrides 7
3.4 Asset / Project Change Control Procedure 8
3.4.1 Who Can Raise an Asset / Project Change Request? 8
3.4.2 How is an Asset / Project Change Request Approved? 8
3.4.3 Where is an Asset / Project Change Recorded? 9
3.4.4 Submission of an Asset Change Request Form 9
3.4.4.1 Assessment of Asset Change Requests 10
3.4.5 Submission of a Project Change Request Form 14
3.4.5.1 Assessment of Project Change Requests 14
3.4.6 Execution and Review of Asset / Project Change Requests 14
3.4.7 Summary of the Asset / Project Change Control Process 15
This document is one of a series of Business Controls adopted by Shell Venezuela S.A. as part of
the SVSA Corporate Management System.
Shell Venezuela S.A. Procedure
October 2004 i
Any printed copy different than the CID hard copy is an "Uncontrolled Copy”– Check web-based version for any revisions
Printed Date 07/01/2005
PROCEDURE FOR VARIANCE, CHANGE CONTROL AND NON-COMPLIANCE REPORTING
Comment and feedback from users of this document is encouraged, by means of the Proposal for
Modification situated at the back of this document, in order that it may be updated as appropriate
to reflect current requirements.
For details of the current revision status of all documents, a summary of intermediate updates
published since the last revision, and information on how to comment on this module, please refer
to the ACIS-CID system.
Copyright
Copyright 2004, Shell Venezuela S.A.
This document is the property of Shell Venezuela S.A. Circulation is restricted to
SVSA and its designated associates, contractors and consultants. It must not be
copied or used for any purpose other than for which it is supplied, without the express
written authority of SVSA.
Except where provided for purposes of contractual requirements, SVSA disclaims any
responsibility or liability for any use or misuse of the document by any person and
makes no warranty as to the accuracy or suitability of the information to any third
party.
Symbols:
Distribution List
This document is available on the SVSA web site at the following address:
http://svsa.americas.shell.com/
Revision Status
On receipt of this document/revision, or notification of update via the intranet, please destroy all
previous and now obsolete copies.
This document is reviewed as a minimum requirement every two years, according to the review
schedule, in the event of changes to SVSA operations or user requirements.
List of Abbreviations
ACIS Assets Control Information System
ALARP As Low As Reasonably Practicable
ANSI American National Standards Institute
API American Petroleum Institute
ASME American Society of Mechanical Engineers (Standards)
ASTM American Society of Testing & Materials
AWS American Welding Society
BSI British Standards Institute
CEN Comité Européen de Normalisation
CENELEC Comité Européen de Normalisation Electronique
CID Centro de Información y Documentación
CMS Corporate Management System
COVENIN Comité Venezolano de Marcas Industriales
CCR Central Control Room
CRO Control Room Operator
DCS Distributed Control System
EP or E&P Exploration & Production
EPBM Exploration & Production Business Model
ESD Emergency Shut Down
HSSE Health, Safety, Security and Environment
IEC International Electrotechnical Commission
IEE Institute of Electrical Engineers
IT Information Technology
IP Institute of Petroleum
MOPO Manual of Permitted Operations
MOS Maintenance override system
MPP Main Production Platform
NACE National Association of Corrosion Engineers
NFPA National Fire Prevention Association
PDVSA Petroleos de Venezuela S.A.
SIEP Shell International Exploration and Production
SVSA Shell Venezuela S.A.
TDR Technical Deviation Request
TOF Technical Operations Forum
UW Urdaneta West
Glossary of Terms
1. INTRODUCTION
Shell Venezuela S.A operates a variety of functional assets on behalf of PDVSA. Operation of
these assets is governed by statutory requirements and an established set of policies, standards,
procedures, guidelines and plans. On occasion, it may be necessary to:
• vary from established, documented practices and statutory requirements
• make changes to projects in order to improve design integrity
• make changes to assets in order to ensure continued safe and efficient operation (technical
integrity).
This document defines the procedures to be followed in the event of:
• an unplanned non-compliance with Venezuelan statutory requirements and/or SVSA/Shell
Group policy and/or SVSA standards and procedures.
• a planned variance from Venezuelan statutory requirements and/or an SVSA policy, standard
or procedure, where this is considered to be warranted.
• a planned change to projects/activities or assets (during PIN, CTR or execution stage), where
this is considered to be warranted and can be justified on technical, HSSE and/or cost
grounds.
All changes to SVSA policies, standards, procedures or guidelines follow the procedure
documented in:
C02.01.04-02-ST01 Document Management System Manual
The process by which plans are changed / updated is described in:
C02.01.06-00-ST01 Corporate Management System Manual (section 6.1.3.4)
C01.03.00-00-GU01 Asset / Activity Planning & Management
Throughout this document the term “facilities” denotes SVSA functional assets whilst
projects/activities cover both natural and functional assets.
1.1 Objectives
The objective of this document is to ensure that an auditable process is in place to:
• report and record all non-compliances with established Venezuelan statutory requirements,
SVSA/Shell Group policy and SVSA standards / procedures.
• report, review, evaluate and record all variances from Venezuelan statutory requirements or
an SVSA policy, standard or procedure
• report, review, evaluate and record all changes to projects/activities or assets (incl.
Cancellation of projects/activities) and to the technical integrity of functional assets.
1.2 Scope
This procedure applies to all approved projects, modification activities and operations on SVSA
functional assets, but does not cover changes to documents or plans. There are no exemptions
from this procedure.
1.3 References
Technical Standards are defined in:
P12.00.00-02-ST01 SVSA Surface Facilities Technical Standards, DEPS and Codes of
Practice
The Technical Authorities and the Technical Operations Forum is defined in the:
C02.01.03-03-PR01 Technical Operations Authorities Procedure
1.4 Records
This document contains the following records:
Code Name
Document Code/R1 Name of Record (e.g. Proposal for Amendment)
Document Code/R2 Name of Record #2, etc.
2. RESPONSIBILITIES
The Head of Functional Asset / Activity Management is the executor of this document and as
such is responsible for defining the variance, change control and non-compliance reporting
procedure and ensuring that it is followed. The Operations Manager, Development Manager and
the General Manager are responsible for verifying establishment and monitoring implementation
of the procedure.
3. PROCEDURE
3.1 Definition of Terms
A deviation is a general term that may be sub-divided into three general types:
• Non-compliances
• Variances
• Changes
These deviations are defined in the following table.
Deviation Type Nature Definition
• Non- Unplanned An unplanned deviation from:
compliance • Venezuelan statutory requirement (legislation)
• SVSA/Shell Group policy
• SVSA standard or procedure.
• Variance Planned A planned deviation from:
• Venezuelan statutory requirement (legislation)
• SVSA/Shell Group policy
• SVSA standard or procedure.
• Change Planned A reported, approved deviation that results in a change to an
asset. A change may apply to:
• an existing Asset, or
• a Project / Activity.
REPUTATION
ENVIRONMENT
ASSETS
Any planned variance from Venezuelan statutory requirements must be discussed with the
relevant authorities, via established communication channels.
C02.01.06-00-ST01 Corporate Management System Manual (section 6.1.1, table 7)
It is the responsibility of the VP of Legal to maintain records of all planned variances with
legislation (whether rejected or approved). Variances with relevant legislation are recorded in the
following documen (SVSA Legislation Record):
C01.02.01-03-ST01 Registro de Legislación
Venezuelan statutory requirements for environmental discharge limits are documented in:
S02.01.05-03-ST06 Legal Environmental Standards
Any planned variance (including those from statutory discharge limits) must follow the procedure
detailed in the following flowchart.
A2 Collate information,
record on PVR
A3 Determine consequence
severity in conjunction
with Technical Authority
A4 Consequence severity Yes
4 or 5?
A5 Review PVR, No
agree actions
A7 Review PVR, No
agree actions
A8 Review PVR
agree actions
A9 Discuss planned
variance with authorities,
agree actions
Reject
A10 PVR rejected / approved
Approve
A11 Maintain register of
rejected PVRs & reasons
for rejection
Figure 2: Process Flowchart for Planned Variance from Venezuelan Statutory Requirements
A1 Identify variance
A2 Collate information,
Submit PVR
A7 Maintain register
of approved non-
technical PVRs
Figure 3: Process Flowchart for Planned Variance from SVSA Policies, Standards & Procedures
Routine overrides
Overrides for preventive and corrective maintenance:
Overrides on ESD and FGS associated instrumentation for performing preventive and corrective
maintenance tasks. These overrides should have a duration of less than 24 hrs, unless
equipment or plant is shutdown and isolated following the permit to work procedure.
Maintenance Technicians will carry out a risk analysis to evaluate which element(s) must be
overridden to execute preventive and corrective routine and to assess if remaining mitigation
barriers in place are adequate to ensure that risks involved during job execution are kept ALARP.
Maintenance Lead technicians will reflect outcome of risk analysis on toolbox minute.
Maintenance Lead technicians will reflect outcome of risk analysis on toolbox minute. Required
inhibitions shall be reflected in the permit to work. Overrides for preventive maintenances shall be
included in the maintenance routines.
Overrides for routinely operations:
Overrides on ESD and FGS detection associated instrumentation for performing operational
tasks, i.e. crude/gas sampling for laboratory analysis, plant/equipment start up and shutdown.
These overrides should be included in operational procedures, supported by a risk analysis to
ensure safe conditions during job execution.
Non-routine overrides
If the duration of an override on ESD and FGS associated instrumentation/equipment on a live
process exceeds 24 hrs it shall be considered to be non-routine, unless this condition is covered
by the MOPO and recommended actions have been executed. An example is: Temporarily
operating a well having a surface safety valve overridden, awaiting for spare parts or specialised
technical assistance.
Authorisation
For routine overrides on MPP, field facilities and Ule terminal the level of authorisation is the
Asset Executor or his delegate.
For non-routine overrides, risks must be evaluated using the Risk Assessment Matrix (Fig 1). If
ranked risks are in the blue area (Continuous Improvement), the level of authorisation will be the
Asset Executor or his delegate. If evaluated risk is in the yellow area (Demonstrate ALARP), the
Asset Executor or his delegate can only authorise a 24-hour exemption until a Variance is
authorised for continuous operation. If ranked risk is in the red area (Intolerable) the evaluated
override shall not be set.
Overrides are logged on a white board in the MPP CCR, updated on a daily basis by the CRO
and listed in the Technical Integrity Weekly Report.
All changes that may affect HSE, Quality, Technical Integrity or Economic Value (budget,
schedule, production, reserves) of a project/activity must be controlled. Examples of
project/activities or asset changes include, but are not limited to the following:
• Any changes to the project/activity basis for design (incl. changes to project/activity
economics)
• Any change to the original (asset) design intent
• Any change to the physical configuration of structures, systems or equipment
• The physical substitution of any item of equipment by an alternative that is not identical to the
original (i.e. non-like for like replacement)
• Permanent removal from service of any system or item of equipment
• The temporary or permanent addition of any system or item of equipment
• Addition / removal of well / well control equipment
• Any alteration to material specification
• Any alteration to hazardous area classification boundaries
• Any change to a P&ID
involvement of all relevant parties such that all impacts on HSE, Technical Integrity, Quality
and Economic Value of the project/activity are considered.
• Technical Operations Forum (TOF): assesses and endorses / rejects the ACR / PCR based
on the foregoing justification and a technical / HSSE review. The TOF ensures that neither
technical nor HSE integrity is compromised and reviews the cost element associated with the
technical change.
• Operations Manager, Development Manager: approves Project Change Requests endorsed
by the TOF. Note; Asset Change Request requires approval from Operations Manager only
Note: Non-technical changes which have no impact on technical integrity do not require review
by a Technical Authority and the TOF. These are referred directly by the Activity Executor, via the
line, to the Asset Custodian / Holder for review, approval and endorsement.
C02.01.03-03-PR01 Technical Operations Authorities Procedure
Authority ACR.
An example of an Asset Change Request Form is given in Attachment 2.
Production Operability
A1 7.00 A1 1.60
A2 8.75 A2 2.00
A3 10.50 A3 2.40
B1 8.75 B1 2.00
B2 10.50 B2 2.40
B3 14.00 B3 3.20
C1 10.50 C1 2.40
C2 14.00 C2 3.20
C3 19.25 C3 4.40
D1 14.00 D1 3.20
D2 19.25 D2 4.40
D3 26.25 D3 6.00
Example:
Potential Benefits
Production Operability
Manpower Materials / Equipment
Risk assessment: C3 B1 A2
Benefit 19.25 2.00 2.00
Overall Production & 19.25 + 2.00 + 2.00 = 23.25
Operability Ranking
Example:
Potential Cost of Asset Change
Cost Resource
< USD10,000 Minor project
Ranking 4.50 3.50
Overall Cost & 4.5 + 3.50 = 8.00
Resource Ranking
Overall Ranking
The overall ranking for an Asset Change Request is determined by the Technical Operation
Forum, based on an evaluation of individual rankings for HSSE, Production & Availability and
Cost & Resource. The overall Cost Benefit ratio is determined as follows.
Example:
Benefit / Cost
HSSE Ranking 19.25
Production & 23.25
Operability Ranking
Cost & Resource 8.00
Ranking
Cost Benefit Ratio (19.25 + 23.25) / 8.00
= 5.31
All Asset Change Requests with a cost benefit ratio of less than 3 are carefully examined to
determine if the expenditure is justified.
Final
Assessment Fixed Adjustable
High
High
High
Low
Low
Welfare
Low
Low
Low
Executor actions the Project Change Request and incorporates any necessary changes in
existing Workpacks. The Project Change Request is signed off by the Project Manager once the
job is satisfactorily completed.
Review
All completed Asset / Project Changes are reviewed at the following Technical Operations Forum
meeting to verify that initial objectives have been satisfied within the defined cost / resource
parameters.
P
Ori Op A A
Te C CuC
gin Ex er C Ex Ho R: M
Ac
at ec
ch Fo
ati R /ec R: sto an
lde Pr
tivi
or ut
nic ru
on P ut As dia ag
r / oje
ty or al m set n
/ s C or ct er
A2 Collate information,
Submit ACR / PCR
No
Yes
A8 Compile / update
Workpack
A10 No
Work Completed?
Yes
No
A11 Drawings Update?
Yes
Signed: Date:
Supported by: Reference Indicator: Date:
Technical Authority
PART B – For Planned Variance with Legislation only (return form to LPA)
Comments / Agreed Actions / Reasons for rejection (delete as required):
Accepted Rejected
Signed: Reference Indicator: Date:
Management Committee /
Operations Manager /
Development Manager
Comments / Agreed Actions / Reasons for rejection (delete as required):
Accepted Rejected
Signed: Reference Indicator: Date:
Responsible Party -
Stakeholder Communication
Comments / Agreed Actions/ Reasons for rejection (delete as required):
Accepted Rejected
Signed: Reference Indicator: Date:
VP of Legal
Approved Rejected
(send copy of form to Document Executor for
distribution)
Signed: Reference Indicator: Date:
TOF Chairman
Signed: Reference Indicator: Date:
Asset Holder / Custodian
PART D – For Planned Non-Technical Variance only (return form to CID)
Document Title:
Code: Date Reviewed:
Comments / Agreed Actions / Reasons for rejection (delete as required):
HSSE Ranking: Production & Cost & Resource Cost Benefit Final
Operability Ranking: Ratio: Assessment:
Ranking:
Approved Rejected
Signed: Reference Indicator: Date:
Chairman TOF
Signed: Reference Indicator: Date:
Asset Holder / Custodian
HSSE Implications:
Drawings: (specify)
Signed: Date:
Supported by: Reference Indicator: Date:
Technical Authority
PART B – To be completed by Technical Operations Forum
Date Reviewed:
Comments / Agreed Actions / Reasons for rejection (delete as required):
Approved Rejected
Signed: Reference Indicator: Date:
Asset Holder / Custodian
Signed: Reference Indicator: Date:
Chairman TOF
Copy:
Title: Procedure for Variance, Change Control Document No. C02.01.05-04-PR01
and Non-Complaince Reporting
Proposal:
Justification:
Date:
Comments/Action:
Operations Manager:
Date:
Document Code/RX
Requests for amendments to the document should be directed to the Document Custodian, the
Operations Manager via the Document Executor, the Head Functional Asset and Activity
Management. All changes to the document require the approval of the General Manager, the
Document Owner.
The “Web Publication Form” is not part of the document, for this reason you have to removed the
format for signature and after you have to send it together with the document to the CID.