Rashpetco PSI Gap Analysis Fully Compliant

OSHA (29CFR1910.119), CCPS, EI, BG Partially Compliant

Section 1 Process Safety Information Non-Compliant

Clause Subject PSI Standard Requirement Relevant Sta Notes JV Stakeholder -

Rashpetco tus Location
Documents

OSHA Process The OSHA PSI Overview shall

Safety compromise the following:
Information
Hazardous chemicals information in MSDS These documents have been reviewed Flow Assurance/Process
the process shall consist of at least as appropriate, but it is not possible to – Cairo
the following: confirm that all assets are covered.
• Toxicity, There is concern that a number of Project GM/OPS GM –
• Permissible exposure limits, flowlines etc are in either of these Cairo (Interface
• Physical data, documents. /Documentation Update)
• Reactivity data,
• Corrosivity data, and
• Thermal and chemical stability
data, and hazardous effects of
inadvertent mixing of different
materials.
Process Information must include at
least the following:
• A block flow diagram or simplified
process flow diagram,
• Process chemistry,
• Maximum intended inventory,
• Safe upper and lower limits for
such items as temperatures,
pressures, flows or compositions,
and
• An evaluation of the
consequences of deviations,
including those affecting the safety
and health of employees.
Equipment Information in the A document was available looking at the SOT (Inspection) - Cairo
process must include the award of a contract that would have
following: included a GIS platform. Rashpetco to
• Materials of construction, confirm if this wa actually awarded, and
• Piping and instrument diagrams advise on implementation if so.
(P&IDs),
• Electrical hazard area
classification
• Relief system design and design
basis,
• Ventilation system design,
• Design codes and standards
employed,
• Material and energy balances for
processes built after May 26,
1992, and
• Safety systems (e.g., interlocks,
detection, or suppression systems).
A description of pipeline system No single document is available. Include OPS GM/Technical GM -
ownership and operator this with GIS project mentioned above. Cairo
responsibility in relation to
upstream and downstream assets;
A flowchart describing the PIMS Not Available
process;
A summary of the PIMS Annual No evidence of this being undertaken.
Assessment Process for Continued
Operation (AAPCO);
Summary of AAPCO Review No evidence of this being undertaken.
outcomes, including any contingent
inspection and remediation for the
coming 12months;
Summary of Statutory and Not Available
Regulatory obligations due within
the next 36months.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially Compliant
Section 2: Regulatory & BG Group Requirements Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Rashpetco Status Notes JV

Documents Stakeholder -
Location

6.3.2.1 Regulatory & The PIMS shall comprise a detail register Inspection
BG of BG Group requirements and statutory AGM – Cairo
Requirements and regulatory obligations with respect
to the design, operation and de- Asset Integrity
commissioning of the pipeline system. – Cairo/Idku
This shall include the following:-
a) BG Group: BG & Rashpetco Copies of HSSE bi-annual OPS
· Details of BG Group Standards; Standards available audits, ISFR-RR7 reviews & GM/Technical
· BG Group HSSE bi-annual audits; and can be GTA pipeline audits require to GM - Cairo
· ISFR – RR7 Reviews; referenced. be provided and referenced
· GTA Pipeline audit and review as
required by this standard.
b) Statutory and Regulatory Obligations: A list of Further information required OPS
· Statutory obligations and requirements Environmental on National and other GM/Technical
as required by local and federal laws; Legislation and applicable Legislation or GM – Cairo
· Regulatory and Permit obligations and Requirements is other Regulatory
requirements as covered by local licence available as a requirements for the HSE GM –
to operate and hydrocarbon reference document. transportation of Cairo
transportation; Environmental Legal hydrocarbons within Egypt.
· Obligations arising from the Register
Environmental Management Plan. RPC-HSE-MS-XXX-XX-
XX

c) The above shall be shown on a
Timeline for the following:
· Planned Reporting Dates;
· Planned Audits and Review;
· Planned updates to PIMS.
Not currently available
A programme will require to
be developed showing
planned dates for reporting,
auditing & updating of the
PIMS Framework document
6.3.2.2 Section 2 shall be maintained as living Not relevant at this Once the PIMS Framework
documents and reviewed annually and stage document has been
updated as necessary as part of the developed it will require
Annual Assessment Process for annual review & update & will
Continued Operation (AAPCO) and signed be used within the AAPCO
off as relevant, accurate and complete by process.
the Asset Operations Manager.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially Compliant
Section 3: Roles & Responsibilities Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder -
Documents Location

6.3.3.1 Roles & The roles and responsibilities shall be clearly Not currently Not provided OPS
Responsibilities defined for the Technical Integrity and for available GM/Technical
Operations each section of the pipeline network. GM – Cairo

6.3.3.2 The Asset Operations Manager, or other person Not currently Competence matrix CAMS Manager
nominated in this Functionally Critical Role, will available required - Idku
hold single point accountability for the operation
and integrity of the pipeline system. The Asset
Operations Manager shall ensure that all
personnel in the organisation are competent and
have the tools and support for the work
requested of them.
6.3.3.3 The following shall be developed and updated Not currently Training & competency CAMS Manager
annually based on the pipeline operating available programme required. - Idku
procedures:-
· A defined training and competency assessment Competence matrix
programme for all key tasks defined in the required
pipeline operating procedures.
· A register of all personnel (staff and
contractors) qualified as competent to
undertake key tasks defined by the pipeline
operating procedures. All supervisory staff in
the field shall attain the same level of
competency (or higher) than the personnel
undertaking the key tasks defined by the
operating procedure.
6.3.3.4 The day to day technical integrity of the Pipeline Rashpetco Statement on reporting OPS
System will be managed by the ATA Pipelines PowerPoint on lines & organisational GM/Technical
and will report directly or indirectly to the Asset Management & structure required. GM – Cairo
 Integrity Manager, who in turn will report Operations Sept
directly or indirectly to the Asset Operations 2013
Manager.
6.3.3.5 Section 3 shall be maintained as a living Not relevant at Once the PIMS Framework
documents and reviewed annually and updated this stage document has been
as necessary as part of the Annual Assessment developed it will require
Process for Continued Operation (AAPCO) and annual review & update &
signed off as relevant, accurate and complete by will be used within the
the Asset Operations Manager. AAPCO process.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially Compliant
Section 4: Basis of Design & Operation Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder -
Documents Location

6.3.4.1 Basis of The PIMS shall comprise a current version of the Rossetta Field 24" shorelink, 65km, Production &
Design & Basis of Design and Operation (BODO) for the Development, some key elements Flow Assurance
Operation pipeline system, comprising as a minimum, the Pipeline Design not provided. – Cairo
following key elements: Premise
· System Description, comprising a summary of 2617-240-300-202 OPS
section 6.3.6; Rev.0 1998 24" onshore, 26km, GM/Technical
· Operating History (including fluid properties over some key elements GM – Cairo
time); Rossetta Field not provided
· Engineering Design and Process Description; Development, BOD
· Pipeline Flow Assurance parameters, constraints for 24" onshore line.
and performance requirements; 2617-200 Rev.1 Infield pipelines & Engineering
· Pipeline mechanical design parameters and 1999 flowlines. Manager - Cairo
assumptions;
· Environmental, Soil and Geohazard data; Rossetta Field
· Pipeline Operating Philosophy; Development Ph3 &
· Safe operating envelope description; Infill Wells,
· Corrosion Management Strategy; Design Criteria for Limited description.
· Inspection and Maintenance Philosophy; Offshore Pipelines
· Defects Assessment Plan. 7716-491-60-RT-
001 Rev 4 2007
2off 20" infield
Rossetta Operating pipelines
Envelope 24" & 36" shorelinks,
RPC-MS-OPS-ENG- 86km
001 Rev.4 2010 30" onshore pipeline,
26km
WDDM,
Scarab/Saffron
Development Second 36" shorelink,
Project, Ph1, BOD 86km installed during
 24419-00L-MOR- WDDM Ph7, BOD
000-00001 Rev 3 details not provided.
2001

WDDM Operating
Envelope
RPC-MS-OPS-BFG-
025 Rev.17 2013

Corrosion
Management &
Material Selection
Strategy
RPC-OPS-MS-ENG-
413 Rev.0 2011
6.3.4.2 The BODO shall contain and highlight any design Management of Design assumptions Production &
assumptions or interface conditions that maybe Change Procedure and interface Flow Assurance
subject to change and provide a basis for review and RPC-HSE-MS-CNG- conditions subject to – Cairo
management of change. 48-02 Rev.3 2012 change are not
identified. OPS
Engineering Change GM/Technical
Management GM – Cairo
Procedure
RPC-MS-OPS-ENG-
423 Rev.2 2005
Engineering
Subsea Operations Manager - Cairo
Management of
Change Procedure
RPC-SOT-MS-PRO-
3001 Rev.2 2013

Subsea Software
Management of
Change Procedure
RPC-SOT-MS-PRO-
4001 Rev.2 2011
6.3.4.3 The BODO shall clearly state any future None identified None identified OPS
requirements or obligations at a fixed date (e.g. GM/Technical
change of ownership or statutory defined audits or GM – Cairo
 upgrades).
6.3.4.4 Section 4 shall be maintained as living documents Reviews occur. OPS
and reviewed annually and updated as necessary as Procedure not GM/Technical
part of the annual formal assessment process for provided. GM – Cairo
continued operation (AAPCO) and signed off as
relevant, accurate and complete by the ATA Pipelines
and Asset Operations Manager.
 Rashpetco PIMS Gap Analysis Fully
Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially
Compliant
Section 5: Pipeline Operating Procedures Non-
Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV Stakeholder -

Rashpetco Location
Documents

6.3.5.1 Pipeline A procedure for maintaining and updating Operating Not provided Production & Flow
Operating Procedures shall be clearly stated. Assurance – Cairo
Procedures
6.3.5.2 Formal operating procedures shall be in place, focusing Sapphire South Operating Production & Flow
on operating within safe operating limits and the Central (SSC) HIPPS procedures not Assurance – Cairo
operating response to an anomaly or incident. This Dossier (Subsea) provided
shall be clearly linked to the Basis of Design and RPC-SOT-ENG-DOC- Instrumentation
Operation (BODO). 4002 Rev.0 T.A. – Cairo

Emergency &
HSE - Cairo
Incident Response
Plan
RPC-MS-OPS-INC-
401 Rev.DRAFT
2000

Subsea and Land

Based Pipeline
Emergency
Response
RPC-MS-OPS-INC-
405 Rev.DRAFT
2000

IDKU Emergency
Response Plan
RPC-MS-OPS-HSE-
 312-2 Rev.0 2010

IDKU Gas Hub

Upstream: Onshore
Emergency
Procedure
RPC-OPS-MS-HSE-
TEMP002 Rev.1
2005

Incident Reporting &

Investigation
Procedure
RPC-HSE-MS-IRI-
411-00 Rev.1 2012
6.3.5.3 Procedures shall address how pipeline risks and Operational Risk OPS GM/Technical
condition are managed over time and how these are Assessment GM – Cairo
reviewed and assessed. Procedure
RPC-MS-OPS-HSE-
305-3 Rev.0 2013
HSE - Cairo
6.3.5.4 Separate operating procedures shall be developed for Corrosion Not provided Production & Flow
managing the following: Management Assurance – Cairo
· Commissioning; strategy provided,
· Wax; no supporting QA/QC – Cairo
· Hydrates; procedures.
· Blow down;
Inspection AGM –
· External Corrosion;
Cairo
· Internal Corrosion;
· Pigging;
· Liquid Inventory; SOT Inspection -
· Decommissioning. Cairo
6.3.5.5 Reference shall be made to the PIMS Management of Not relevant at this Pending for
Risk section 6.3.9. stage PIMS
6.3.5.6 Section 5 shall be maintained as living documents and Not relevant at this Reviews occur.
reviewed annually and updated as necessary as part of stage Procedure not
the annual formal assessment process for continued provided.
operation (AAPCO) and signed off as relevant, accurate
and complete by the Asset Operations Manager.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially Compliant
Section 6: Document & Data Management System Non-Compliant

Claus Subject PIMS Standard Requirement Relevant Status Notes JV

e Rashpetco Stakeholder
Documents - Location

6.3.6.1 Document & The document and data management system shall Not known Need to request further OPS
Data comprise a GIS database, based on a PODS metadata info from Rashpetco GM/Technical
Management structure, overlaying a series of relational databases. GM – Cairo
System Paper copies maybe held for reference, although the GIS
will form the main data repository in electronic format.
This shall be in addition to the minimum requirements of
HSSE Documentation Management Standard BGA-HSSE-
GEN-ST-0502.
Typically, the industry adopts ArcInfo ESRI based HSE - Cairo
software tools based on a PODS metadata.
6.3.6.2 Document control procedures shall be development, Not known Need to request further OPS
documented and operated for the PIMS. This shall include info from Rashpetco GM/Technical
procedures for data entry, quality control, management GM – Cairo
of change, data access and security rights.
6.3.6.3 The Document and Data Management system should Not known Need to request further OPS
have the ability to interface with the Asset Maintenance info from Rashpetco GM/Technical
Management System and other asset management GM – Cairo
systems (e.g. MAXIMO or CMMS/GWMS etc).
6.3.6.4 The Document and Data Management system shall be Not known Need to request further OPS
able to manage data relevant to the following: info from Rashpetco GM/Technical
· System description; (see section 6.3.6.5); GM – Cairo
· Asset register; including Engineering Design and
Construction QA/QC As-Built Data (see section 6.3.6.6);
· Production and Inspection Records. (section 6.3.6.7);
· Asset Repairs and Remedial Action (section 6.3.6.8).
6.3.6.5 The system description shall comprise the following: Not known Need to request further OPS
· Clear definition of the pipeline system limits and info from Rashpetco GM/Technical
 interfaces, with a description of design limits, input and GM – Cairo
output flow rates, fluid compositions and pressures at
upstream and downstream interfaces and the operating
envelope;
· A pipeline system may comprise a number of pipelines.
Each pipeline within the system shall be defined within
the network;
· Interfaces shall describe pipeline asset ownership
boundaries. (A PIMS may cover pipeline system covering
pipelines owned by more than one company);
· Interfaces shall be defined by a physical location for
inspection schemes and responsibilities, including
interfaces between:
- PIMS and WIMS;
- PIMS and surface facilities AIMS;
- PIMS and other connecting pipeline systems outside of
the PIMS scope.
- All interfaces shall have a defined process for the
communication and transfer of information.
6.3.6.6 The Asset Register shall comprise the following Not known Need to request further OPS
Engineering Design and Construction QA/QC As-Built info from Rashpetco GM/Technical
data:- GM – Cairo
· Current Basis of Design and Operation (BODO);
· 3D Polyline Data defining the pipeline location;
· Georeferenced Satellite or Bathymetric Mapping;
· Geohazard and Environmental Constraint Mapping;
· Environmental Impact Assessment;
· Current Environmental Management Plan;
· As-Built Drawings, including Alignment Sheets;
· As-Built PFD and P&ID;
· As-Built geo-referenced Material
Specifications/Certificates;
· As-Built geo-referenced Weld Test QA/QC Data;
· As-Built geo-referenced Line Pipe Tracking, with cross
reference to material certificates;
· Vendor data and As-Built mechanical equipment data;
· SCADA and C&I Data;
· System Protection data;
· Management of Risk data as defined in section 6.3.9.6;
· Hydrotest Records;
 · Commissioning Records;
· Re-instatement Records;
· Landowner and Stakeholder Records (if appropriate);
· As-Built survey data.
6.3.6.7 The Production and Inspection records shall comprise the Not known Need to request further OPS
following: info from Rashpetco GM/Technical
· Operating History (Composition, Pressures, Volumes, GM – Cairo
Temperatures);
· Incident Reports as per section 6.3.11.2;
· Inspection Test Plans;
· Defects Assessment;
· Emergency Response Materials and Equipment
Inventory.
6.3.6.8 The Asset Repairs and Remedial Action records shall Not known Need to request further OPS
comprise the following: info from Rashpetco GM/Technical
· Defects Assessment Reports (DAR); GM – Cairo
· Remediation Action Plans (RAP);
· Repair Inspection Reports (RIR), signed off by an
independent professional engineer (e.g. C.Eng; PE;
P.Eng, CPEng, RPEQ, or Dipl.Ing for example);
· Details of All Remedial Repairs following Inspection and
Defects Assessment, inputting to an updated BODO;
· Details of System Upgrades and Modifications inputting
directly into an updated BODO;
· Recommendations for modifications to RBI regime;
· The Annual Barrier Statement as defined by the BG-ST-
HSSE-AI-004 shall be updated on completion of the
above.
6.3.6.9 The Document and Data Management System shall be Not relevant Once the PIMS
reviewed annually and updated as necessary as part of at this time Framework document
the annual assessment process for continued operation has been developed it
(AAPCO) and signed off as relevant, accurate and will require annual
complete by the ATA Pipelines and Asset Operations review & update & will
Manager. be used within the
AAPCO process.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially Compliant
Section 7: Structural & Mechanical Integrity Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder
Documents - Location

6.3.7.1 Structural & The Structural and Mechanical Integrity process shall
Mechanical comprise three stages:
Integrity
Inspection Plan and Written Scheme of Examination; Inspection
AGM – Cairo

SOT
Inspection -
Cairo
Defects Assessment; Inspection
AGM – Cairo

SOT
Inspection -
Cairo
Defect Reporting and Remediation Plans; Inspection
AGM – Cairo

SOT
Inspection -
Cairo
6.3.7.2 Inspection Plan and Written Scheme of Examination;
A clear Inspection Plan and Written Scheme of Some plans in place. Not Inspection
Examination shall be developed for the pipeline possible to confirm if all AGM – Cairo
system. The basis of the plan will be clearly stated and are available.
will be based on a Risk Based Inspection philosophy; SOT
Inspection –
Cairo
 Asset Integrity
– Cairo/Idku
Each section of the pipeline system shall be identified Not possible to confirm if Asset Integrity
as a discrete element and risks associated with each. all in place due to – Cairo/Idku
Critical pipeline sections or areas of higher risk shall fragmented nature of
be identified; documents
Where possible, Risk Based Inspection (RBI) plans Evidence seen that RBI Inspection
shall be developed for each section of the pipeline approach has been used, AGM – Cairo
system, describing: but not possible to
confirm if it fully meets SOT
the BG Group standard Inspection –
Cairo

Asset Integrity
– Cairo/Idku
* Method of Inspection Inspection
AGM – Cairo

SOT
Inspection –
Cairo

* Frequency of Inspection Inspection

AGM – Cairo

SOT
Inspection –
Cairo

* Defects Acceptance Criteria to be used; Inspection

AGM – Cairo

SOT
Inspection –
Cairo

* Interface overlaps and information exchange with Inspection

 WIMS, surface facilities AIMS and connecting AGM – Cairo
pipelines.
SOT
Inspection –
Cairo

* Inspection programmes for rigid pipelines operating Inspection

at greater than 16bar shall be in accordance with BG- AGM – Cairo
ST-OPS-T&D-003;
SOT
Inspection –
Cairo

* Guidance should be sought from the GTA Flexibles Inspection

and Dynamic Risers for the development of inspection AGM – Cairo
programmes for Flexibles and Dynamic Risers.
SOT
Inspection –
Cairo

6.3.7.3 Defects Assessment for all rigid metallic pipelines shall Inspection
be based on the following: AGM – Cairo

SOT
Inspection –
Cairo

Pipeline Defects assessment will be based on the None seen Inspection

requirements of the THE PIPELINE DEFECT AGM – Cairo
ASSESSMENT MANUAL (PDAM): June 2006;
SOT
Inspection –
Cairo

Clear reporting lines shall be established prior to Inspection

undertaking remedial/repair action in the event of a AGM – Cairo
potential Defect being identified;
SOT
 Inspection –
Cairo

Defects Assessment shall be undertaken by a qualified Need to see register of Inspection

professional engineer, trained in the use of PDAM people and review defect AGM – Cairo
techniques; assessments undertaken
to verify that all have SOT
been undertaken by Inspection –
someone from the register Cairo

All defects assessment in pipelines operating at Need to see register of Inspection

pressures above 16bar shall be verified by an people and review defect AGM – Cairo
independent professionally qualified engineer trained assessments undertaken
in the use of PDAM techniques; to verify that all have SOT
been undertaken by Inspection –
someone from the register Cairo
The results of all defects assessment activities will be Need to see register Inspection
presented in a formal Defects Assessment Report AGM – Cairo
(DAR) and remediation actions logged onto a
Remediation Action Plan (RAP). Both the DAR and RAP SOT
shall be automatically fed into the Management of Inspection –
Change process and Asset Maintenance Management Cairo
System.
Engineering
Manager-
Cairo
6.3.7.4 Defects Assessment for all non-metallic pipelines N/A for Rashpetco Engineering
operating up to and including 16bar shall be based on Rashpetco to confirm if Manager-
the requirements contained within BG-ST-OPS-T&D- non-metallic pipelines are Cairo
002. in use below 16 Bar
6.3.7.5 Defects Assessment of Dynamic Steel Risers and None seen Inspection
Flexibles shall be in accordance with the requirements AGM – Cairo
of BG-ST-ENG-RISE-001 and BG-ST-ENG-RISE-002.
Guidance should be sought from the GTA Flexibles and SOT
Dynamic Risers. Inspection –
Cairo

Engineering
 Manager-
Cairo
6.3.7.6 Defects Reporting and Remediation:
a) Defects identified in a RAP requiring repair shall be Inspection
remediated/repaired within 6months of the defect AGM – Cairo
being identified, unless supported by a risk based
justification. SOT
Inspection –
Cairo

b) All defect remediation/repairs shall be inspected Inspection

immediately on completion of the repair and a Repair AGM – Cairo
Inspection Report (RIR) issued for review by the ATA
Pipelines. SOT
Inspection –
Cairo

c) The RIR shall be certified by an independent Inspection

professional engineer as meeting the defects AGM – Cairo
acceptance criteria as defined in section 6.3.7.2, and
signed off as input to the year-end AAPCO. SOT
Inspection –
Cairo

d) The DAR and RAP shall be fed back to the Basis of Inspection
Design and Operations under the Management of AGM – Cairo
Change process.
SOT
Inspection –
Cairo

e) The risk criteria used for RBI shall be reviewed in Inspection

the light of information gained from repairs and fed AGM – Cairo
back into the Management of Change process.
SOT
Inspection –
Cairo
 Engineering
Manager-
Cairo
6.3.7.7 A formal assessment of the Structural and Mechanical Report not seen Inspection
Integrity of the Pipeline System and the shall be AGM – Cairo
undertaken on an annual basis, providing a
recommendation for continued operation, or further SOT
remediation action in support of further operation. RBI Inspection –
Plans shall be reviewed and updated as part of this Cairo
review. The Asset Operations Manager and ATA
Pipelines shall sign off the Pipeline System annually as
fit for continued operation at the end of each calendar
year as per section 7.0.

Due to the nature of the information required to be reviewed for this section, it has not been possible to complete this task remotely. It is recommended
that a face to face meeting is undertaken to allow discussion and review of the data required to confirm if Rashpetco fully meets the BG Group standard.
If a face to face meeting is not possible, it may be feasible to do this via video conference.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially
Compliant
Section 8: System Protective Systems Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder -
Documents Location

6.3.8.1 System Pipeline protection systems shall be identified, Sapphire South Limited Instruments
Protective documented, inspected and tested in accordance with BG Central (SSC) documentation T.A. - Cairo
Systems Standard BG-ST-ENG-PROC-015. HIPPS Dossier provided.
(Subsea)
RPC-SOT-ENG-
DOC-4002 Rev.0
6.3.8.2 Records of all assessment and maintenance and testing Not provided. OPS
shall be retained within the document management GM/Technical
system. GM – Cairo

Instruments
T.A. - Cairo
6.3.8.3 The System protective System shall be reviewed annually Not relevant at Reviews occur.
and updated as necessary as part of the annual this stage Procedure not
assessment process for continued operation (AAPCO) and provided.
signed off as relevant, accurate and complete by the ATA
Pipelines, ATA Control and Instrumentation and Asset
Operations Manager.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially
Compliant
Section 9: Management of Risk Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder -
Documents Location

6.3.9.1 Management PIMS shall affirm the basis and assumptions used for the Not currently Pending PIMS
of Risk Management of Risk for the Pipeline System. It shall also available
state the linkage with RBI input data and define how
changes in Risk profile feed into the RBI process.
6.3.9.2 The Management of Risk shall be undertaken in Operational Risk
accordance with BG Standard BGA-HSSE-GEN-ST-0201 Assessment
and Quantitative Risk Assessment shall be based on BG Procedure
Guideline BG-GL-HSSE-AI-011. RPC-MS-OPS-
HSE-305-3 Rev.0
2013
6.3.9.3 The Management of Risk, including the assessment of Operational Risk
threats, likelihood and consequences shall be addressed Assessment
for the whole pipeline system. Procedure
RPC-MS-OPS-
HSE-305-3 Rev.0
2013
6.3.9.4 The Risk Assessment process shall be clearly defined, Operational Risk
including the assessment processes used for determining Assessment
the frequency of periodic reviews and feedback to the RBI Procedure
process. RPC-MS-OPS-
HSE-305-3 Rev.0
2013
6.3.9.5 A risk register shall be established and updated at least Operational Risk Risk register HSE - Cairo
annually for input to the AAPCO. Assessment required by
Procedure procedure not
RPC-MS-OPS- provided
HSE-305-3 Rev.0
2013
6.3.9.6 The following shall be retained within the Data Not provided OPS
 Management System Documented: GM/Technical
· risk assessments, GM – Cairo
· risk register;
· incident reports;
· lessons learned;
· audits;
· actions taken including linkage to mitigation actions
taken to manage risk;
· changes in input and output data (including
assumptions) to the risk assessment process
6.3.9.7 A formal review of the Risk Management Process, Risk Not relevant at Pending PIMS
Register and Basis for input to the RBI shall be this stage
undertaken on a 6monthly basis and signed off annually
as complete by Asset Operations Manager and ATA
Pipelines as part of the AAPCO process.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially
Compliant
Section 10: Emergency Response Plan Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder -
Documents Location

6.3.10.1 Emergency Emergency Response plans (ERP) shall be developed for Emergency & Interfaces beween HSE- Cairo
Response the operational phase of the project. Incident ERPs are not clear.
Plan Response Plan OPS
RPC-MS-OPS- GM/Technical
INC-401 GM – Cairo
Rev.DRAFT 2000
SOT GM - Cairo
Subsea and Land
Based Pipeline
Emergency
Response
RPC-MS-OPS-
INC-405
Rev.DRAFT 2000

IDKU Emergency
Response Plan
RPC-MS-OPS-
HSE-312-2 Rev.0
2010

IDKU Gas Hub

Upstream:
Onshore
Emergency
Procedure
RPC-OPS-MS-
HSE-TEMP002
Rev.1 2005
6.3.10.2 The ERP shall comprise three main components: Procedures not
· Mobilisation of Resources to investigate the nature and provided for
severity of an incident; Remediation and
· Remediation Action Plans (including plans for pre- Reputation
investment in materials and equipment); Management
· Reputation Management strategies.
6.3.10.3 The ERP shall be tested every 24months as a minimum Not provided OPS
requirement. Testing shall comprise a live drill of a GM/Technical
“mock failure scenario”, comprising resource GM – Cairo
deployment to manage the component activities
identified in clause 6.3.10.2. A “Lessons Learned” report
shall be produced containing a list of any actions for
improvement on completion of the ERP test.
6.3.10.4 A formal review of the ERP and results of ERP Testing Not relevant at Pending PIMS
“Lessons Learned” shall be undertaken on an annual this stage
basis as part of the AAPCO process and signed off by
the Asset Operations Manager.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially Compliant
Section 11: Incident Reporting Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder -
Documents Location

6.3.11.1 Incident All incidents will be investigated and
Reporting reported in accordance with BG
Standard BG-ST-HSSE-EFF-001
6.3.11.2 A register of incidents shall be
developed and maintained within
the Document and Data
Management System.
6.3.11.3 Lessons learned shall be developed
for each incident and communicated
across the asset and to the GTA
Pipelines for wider publication
across BG Group. Lessons Learned
shall be formally incorporated into
the AAPCO.
RPC-HSE-MS-IRI-
411-00 Incident
Reporting &
Investigation
Procedure.
RPC-MS-OPS-INC-
401 EMERGENCY &
Incident
Management Plan.
Incident Register.
Lessons Learned
Reports.
This document was reviewed and
generally meets the requirements of a
good procedure, with the exception of the
reporting of lessons learned. A copy of
the BG Standard was not available to
compare if it meets the BG Group
requirements.
This document has many good HSE- Cairo
procedures contained within it. However,
it is only a draft document dated 2000, so
requires to be updated and completed to
fully meet the intended requirements.
Rashpetco to provide a copy of Incident HSE- Cairo
Register for review. Also to provide a
copy of Audit Report to confirm that all
Incidents have been adequately reported.
The existing procedure only makes HSE- Cairo
recommendations as to who in Rashpetco
requires to be included. It is
recommended that this document be
updated to specify who from BG Group
should be included in these reports.
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE- Partially Compliant
002
Section 12: Management of Change Non-Compliant

Clause Subject PIMS Standard Relevant Status Notes JV

Requirement Rashpetco Stakeholder
Documents - Location

6.3.12.1 Management A formal documented
of Change Management of Change
(MOC) system shall be
established for the pipeline
system based on the
requirements of BG Standard
BG-ST-HSSE-AI-005.
6.3.12.2 Management of Change shall
be reviewed annually as part
of the AAPCO Process.
Management of In principle, this document meets the Engineering
Change Procedure requirements of a fit for purpose MOC Manager-
RPC-HSE-MS-CNG- process, with the following exception. A Cairo
48-02 Rev 3 process flow organisation should be
developed to show exactly where in the MoC Co-
process the detailed design should be Ordinator
undertaken. The flow chart in the Subsea
Software MOC Procedure would be a good
example to base this chart on.
Subsea Operations In principle, this document meets the SOT GM
Management of requirements of a fit for purpose MOC
Change Procedure process, with the following exception. A
RPC-SOT-MS-PRO- process flow diagram should be developed to
3001 Rev 2 show exactly where in the process the
detailed design should be undertaken. The
flow chart in the Subsea Software MOC
Procedure would be a good example to base
this chart on.
Subsea Software This procedure meets the requirements of SOT Controls
Management of the MOC Procedure. It also includes exactly Lead
Change Procedure where in the process that the design should
RPC-SOT-MS-PRO- be undertaken. There are 2 holds in the
4001 document that should be closed out. Both
relate to references to other documents.
Rashpetco to provide copies of the last 2 Engineering
years audit reports, plus evidence of close Manager-
out of the respective actions. Cairo
 Rashpetco PIMS Gap Analysis Fully Compliant
BG Group Standard BG-ST-ENG-PIPE-002 Partially Compliant
Section 13: Performance Management Non-Compliant

Clause Subject PIMS Standard Requirement Relevant Status Notes JV

Rashpetco Stakeholder -
Documents Location

6.3.13.1 Performance A documented performance management Not currently Documented Performance Asset Integrity
Management system shall be established with clear available Management system requires to – Cairo/Idku
and achievable targets for Key be developed.
Performance Indicators (KPI’s) is the
following generic areas:
-System Maintenance (planned and
unplanned interventions);
-Procedure adherence (permits and
pigging frequencies);
-Condition of Valves and Equipment
(testing of safety critical equipment,
repairs or use of clamps);
-Changes in external risk (changes in
Regulatory -Requirements,
permitted and unpermitted
encroachment);
-Non-conformance report tracking;
-Timing of inspections, reporting, follow-
up, reviews and formalised assessments;
-Performance Improvement Plan.
6.3.13.2 The KPI’s will be reviewed on an annual Not relevant at Once the KPIs & the PIMS
basis as part of the AAPCO process. this stage Framework document has been
developed it will require annual
review & update & will be used
within the AAPCO process.