PSST (T-2) Day 2-3 Training Student Manual

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PSST (T-2) Training Student Manual

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Prep Approved Date Page
Allen Matte Richard Jackson 10-06-14 1 of 258
Student Training Manual

PSST Subpart-O
T-2 Training
BSEE 30 CFR 250 Subpart H
Oil & Gas Production Safety Systems
API RP 14C
USCG 33 CFR
API-U Certified Course
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Table of Contents
Table of Contents .................................................................................................................................. 03
Orientation ............................................................................................................................................ 05
Training Objectives ............................................................................................................................... 06
Regulatory Abbreviations .................................................................................................................... 07
Regulatory References-Governmental Links Web Sites ................................................................ 08
API 14C Safety Device Tables 1-10 & Safety Analysis Checklist ................................................... 162
Module One (1) ..................................................................................................................................... 11

Important Abbreviations & Descriptions,
Safety Device Symbols & Lettering Symbols.
Module Two (2) ..................................................................................................................................... 65

Process Variables, (8) Undesirable Events,
Primary & Secondary Protection, Definitions.
Module Three (3) ................................................................................................................................. 80

Emergency Support Systems, Other Support
Systems, Standard Process & Safety Component Definitions.
TSE (Temperature Safety Element) Guidelines ............................................................................ 88
Module Four (4) ................................................................................................................................... 95

API RP 14C Safety System Recommendations,
30 CFR (Code of Federal Regulations) 250 & 254
Subpart A - General Information ........................................................................................................ 98
Subpart C - Pollution Prevention and Control ................................................................................. 95
Subpart D - Oil and Drilling Operations............................................................................................. 105
Subpart E - Casing Management and Diagnostic ............................................................................. 109
Subpart F - Oil & Gas Well Workover Operations ............................................................................ 119
Subpart H - Oil and Gas Production Safety Systems ....................................................................... 120
Subpart J – Pipelines............................................................................................................................. 123
Subpart K - Oil and Gas Production Rates ......................................................................................... 124
Subpart L - Production Measurement, Commingling, and Security ............................................. 126
Subpart N - Civil Penalties.................................................................................................................... 129
Subpart O - Training Requirements T-2 ............................................................................................. 129
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Module Five (5) .................................................................................................................................... 130

Requirements of 30 CFR 250, Subpart H,
Section 803 & API RP 14C.
PSV, PSHL Pressure Settings & Test Tolerances, Sensor Support
Module Six (6) ...................................................................................................................................... 141

Additional Production System Requirements
Module Seven (7) ................................................................................................................................ 148

Required Safety Device Test Schedule .............................................................................................. 149
Allowance Leakage Test Rates
ESD Time Response & Test Records
Module Eight (8) .................................................................................................................................. 153

Safety Analysis Checklists Example Exercises
SAC Reference Tables A.1 – A.10
Safety Analysis Checklist (SAC) ........................................................................................................... 162
Module Nine (9) ................................................................................................................................... 187

Safety System Component
Identification Exercise
Module Ten (10) ................................................................................................................................... 197

Balloon Identification Exercise
Module Eleven (11).............................................................................................................................. 200

United States Coast Guard / BSEE Requirements
Module Twelve (12) ............................................................................................................................. 217

Out-of-Service & Temporary Out-of-Service
Regulations According to 30 CFR 250.803 (c) (1)
Module Thirteen (13) .......................................................................................................................... 232

SEMS (Safety Environmental Management System)
Module Twelve (14) ............................................................................................................................. 242

Safety Device Test Procedures (Hands on Device Testing
PSST Training Manual Table of Contents...................................................................................... 251

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Welcome, Orientation & Sign In

• Student Registration and Verification
• Course Title: T-2 Subpart-O (PSST)
• Emergency Procedures & Exits
• Cell Phones on Silent and or Vibrate,
• No Cell Phone Texting while in class
• Course Requirements and Class Times
• Breaks & Lunch Time
• Break Room and Rest Rooms
• Smoking in Designated Areas
• Three (3) Year Certification

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Course Description and Objectives

This manual is used in the classroom for the PSST (Production Safety System Training) 3-day
Course which is part of the Certification Training Program Courses offered by Falck Safety
Services. Sections of the manual will also be used in the PSST (Subpart-O) Refresher Course.
Method of Presentation and Evaluation

Presentation: For both of the above courses, there is a classroom portion and a practical
demonstration portion required for successful completion of the course. The classroom portion
for these courses will be instructor lead using a PowerPoint presentation and visual aids along
with questions being asked by the instructor and students to check for understanding. The
practical demonstration will be performed in the classroom on a functioning training model.
Evaluation (classroom): Upon completion of the classroom portion of the course(s), the student
will take a 2-hour exam comprised of questions in the format of identify multiple choices,
true/false, fill in the blank, and/or matching. Upon finishing the exam, the instructor will grade
the paper and inform the student of his/her grade. Missed questions will be explained. The
minimum competency requirement for successfully passing the examination is 75%. If a student
fails the exam, one retest will be administered; and if failed also, student will be required to
retake the course. A student failing one refresher exam will be required to take the full 3-day
course.
Evaluation (practical): The student must be deemed competent on all practical demonstration
activities to be deemed competent for the overall practical demonstration thus receiving 100%
on the practical. The hands-on segment assessment will be conducted in four steps. The passing
score for the hands-on exercise will be 100%.
• The instructor will communicate what is expected in the hands-on exercises

• The instructor will demonstrate the exercises to the delegates
• The delegates will participate in the exercises along with the instructor
• The instructor will evaluate the competency of the delegates as they perform the hands-
on tasks unassisted.
Objectives: Upon successful completion of the PSST (T-2) Program, the student will be able to:
• Demonstrate an understanding of the Oil & Gas Production Process

• Develop and Demonstrate an understanding of the Production Safety System, Emergency
Shut Down Systems,
• Provide information to learn the regulations and requirements of 30 CFR 250, 30 CFR 254
and API RP 14C (as they apply to the essentials of Production Safety System Training).
Provide Information on USCG 33 CFR, and SEMS Program API RP 75
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• Show familiarity with the regulations relative to PSST

• Interpret a safe chart to determine how failures or malfunctions in the process system can
cause abnormal operating conditions (AOCs) that must be brought under control by
properly functioning safety devices
• Determine the type of malfunctions or AOCs the class of safety device is intended to
detect or control
• State the basic principles of operation of specific safety devices
• State the limitations affecting the application of specific safety devices
• Identify the problems causing the malfunction of failure of specific safety devices and
determine how to correct them
• Test for proper set points and operation of specific safety devices
• Knowledge on how to record inspection results and malfunctions properly on specific
safety devices
• Adjust, calibrate or reset specific safety devices where applicable
• Demonstrate special techniques for installing safety devices such as orientation, special
lubricants and special installation tools
Prerequisites
This course is open to anyone who needs to be qualified to install, inspect, test, and maintain
surface and subsurface safety devices. Delegates need to be fluent in English (reading, writing
and speaking) and have basic math skills.
Delegates taking the (1) one day T-2 Refresher Course shall meet the following requirements
and provide documentation:
• Six (6) years of offshore (OCS) oilfield experience

• Successful completion of two instructor led Full PSST (T-2) courses
• Be in possession of a current, valid Production Safety Systems (T-2) certification.
Course Length
• The 3-day course will have a lunch break (not included in course time) and a morning and
afternoon break each day. The number of students enrolled in the course will determine
the amount of time needed for the students to complete the practical exercises in the
program.
Below is a list of safety devices the student will have to demonstrate competency in using:
• PSHL, LSHL, TSH, ASH, SSSV, SSV, USV, SDV, FSV, BSL, ESD. PSV, FA, Gas
Make System, SCSSV Hydraulic well panel
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BSEE (Bureau of Safety and Environmental Enforcement) www.bsee.gov

BOEM (Bureau of Ocean Energy Management) www.boem.gov
30 CFR 250.101 Department of Interior authorizes BSEE and BOEM to regulate Oil, Gas, and
Sulphur exploration, development, and production operations on the OCS (Outer Continental
Shelf. BSEE is the governmental agency that enforces Safety and Compliance regulations in the
OCS waters. This will include all Offshore Drilling, Work over, Oil & Gas Production, Sulphur
Operations (30 CFR 250) and Oil Spill Response Requirements (30 CFR 254).
What are the Code of Federal Regulations 30 CFR Part 250 & 30 CFR Part 254 and what
information is found within these Codes of Federal Regulations?
• A collection of federal laws (regulations) compiled by a branch of the Department of
Interior (BSEE) Bureau of Safety Environmental Enforcement that set the minimum
requirements regarding (OCS) Outer Continental Shelf, from the state coast line to the
200 mile federal limit seaward.
Gulf of Mexico Region

BSEE (www.bsee.gov) & BOEM (www.boem.gov) both work to promote safety, protect the
environment and conserve resources offshore through vigorous regulatory oversight and
enforcement. In this effort it is supported by three regional offices: New Orleans, La. Camarillo,
California and Anchorage, Alaska.
These regional offices are responsible for reviewing Applications for Permit to Drill to ensure all
of the recently implemented enhanced safety requirements are met, and for conducting
inspections of drilling rigs and production platforms using multi-person, multi-disciplinary
inspection teams.
BSEE inspectors issue Incidents of Non-Compliance (INC) from the Potential Incident of
Noncompliance (PINC) checklist and have the authority to fine companies and or OCS personnel
through civil penalties for regulatory infractions. Regional and field operations personnel also
investigate accidents and incidents that result injuries and or pollution.
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The Gulf of Mexico Region currently oversees approximately 2500+ offshore oil and natural gas
facilities accounting for nearly 20 percent of the nation's domestic oil production and about 8
percent of domestic natural gas production.
WEB Links:
• API Link: http://api.org

• BSEE Civil Penalties Link: http://www.bsee.gov/Inspection-and-Enforcement/Civil-
Penalties-and-Appeals/Civil-Penalties-and-Appeals.aspx
• BSEE Regulations and Guidance (NTL’s) Link: http://www.bsee.gov/Regulations-and-
guidance/index.aspx
• BSEE Pinc List Regulations: http://www.bsee.gov/Inspection-and-
Enforcement/Enforcement-Programs/Potential-Incident-of-Noncompliance---
PINC.aspx
• BSEE Pipeline Database (Segments)
http://www.data.bsee.gov/homepg/data_center/pipeline/pipelinepermits/master.as
p
• BSEE SEMS: http://www.bsee.gov/Regulations-and-Guidance/Safety-and-
Environmental-Management-Systems---SEMS/Safety-and-Environmental-
Management-Systems---SEMS.aspx
• Code Of Federal Regulations Link: http://www.ecfr.gov/cgi-bin/ECFR?page=browse
• USCG CG-5432 Form: http://www.uscg.mil/forms/CG/CG_5432.pdf
• NRC National Response Center: http://www.nrc.uscg.mil/ or 800-424-8802
• OSHA Link: https://www.osha.gov/
• Petrowiki Oilfield Wikipedia http: petrowiki.org/PetroWiki
• Oilfield Wikipedia http://www.oilfieldwiki.com/wiki/mainpage
• BSEE Safety Violation Hotline number, 1-877-440-0173.
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Subpart-O
(PSST)
Training
Module
1
Important Abbreviations
&
Definitions
Safety Devices, Safety Device Symbols

&
Lettering System
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• What are the Code of Federal Regulations 30 CFR 250 & 30 CFR 254 and
what information is found within these Codes of Federal Regulations?
A collection of federal laws (regulations) compiled by a branch of the Department of Interior

(BSEE) Bureau of Safety Environmental Enforcement that set the minimum requirements
regarding (OCS) Outer Continental Shelf, from the coast line to the 200 mile federal limit
seaward.
BSEE is the governmental agency that enforces Safety and Compliance regulations in the OCS
waters
This will include all Offshore Drilling, Work over, Oil & Gas Production, Sulphur Operations (30
CFR 250) and Oil Spill Response Requirements (30 CFR 254).
• Notices to Lessees and Operators (NTLs)
NTL’s are formal documents that provide clarification, description, supplement
- Provides more detail about certain requirements that emerged from workshops and
discussions or interpretation of a regulation or OCS standard
- Provides guidelines on the implementation of a special lease stipulation or regional

requirement
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- Provides a better understanding of the scope and meaning of a regulation by explaining

BSEE interpretation of a requirement
- NTLs may also outline what you must provide as required information in your various
submissions to BSEE
Departures – Waivers
Approvals granted by the appropriate BSEE or BOEM representative for operating requirements
or procedures other than those specified in the regulations found in this part.
These requirements or procedures may be necessary to control a well; properly develop a lease;
conserve natural resources, or protect life, property, or the marine, coastal, or human
environment
Potential Incidents of Non-Compliance (PINC)
- Checklist items which BSEE inspects to pursue safe operations on the Outer
Continental Shelf. This list of inspection items is derived from all regulations
for safety and environmental standards
Field PINC List (Below List)
Office PINC Same Letters 800+ Decommissioning - A

Field PINC List (Below List) Production - P
Introduction Pipeline - L
PINC List Revisions Measurement and Site Security - M
General - G Hydrogen Sulfide - H
Pollution - E Crane - I
Drilling - D Electrical - F
Well Completion - C Personal Safety (USCG) - Z
Well Work Over – W Appendices (Testing Procedures)
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Example: INC = Incident Of Non-Compliance Violation P-103
P-103
IS EACH SURFACE OR SUBSURFACE SAFETY DEVICE, WHICH IS BYPASSED OR BLOCKED
OUT OF SERVICE, OUT OF SERVICE DUE TO START-UP, TESTING, OR MAINTENANCE AND IS
IT FLAGGED AND MONITORED BY PERSONNEL?
Authority: 803(c)(1) Enforcement Action: C
804(b)
1004(c)
INSPECTION PROCEDURE:
1. Visually inspect the safety system and identify safety device(s) that are out of service
and observe to see if they are flagged and monitored by personnel.
2. Discuss out of service safety devices with the operator to verify that each is out of service only
due to start-up, maintenance, or testing.
3. Verify that only a minimum number of safety devices are taken out of service.
IF NONCOMPLIANCE EXISTS:
Issue a component shut-in (C) INC for the component protected by the safety device when the
safety device is out of service for reasons other than for maintenance, start-up, or testing, and is
not flagged or monitored by personnel.
INSPECTION COUNT/ INC COUNT:
Enter one item checked/ issue one INC per device inspected
American Petroleum Institute, Recommend Practice 14C (API RP 14C) is a private

organization that can only recommend certain practices and standards
BSEE Through 30 CFR 250.198 directs that designated API RP documents are incorporated
by reference for use in OCS operations and enforcement.
These are standards used for guidance for a safe operation of all platforms or process
facilities
What subjects are referenced in API RP 14C?
It is the American Petroleum Institute Recommended Practice 14C, guidelines for the
analysis, design, installation, and testing of basic surface safety systems for offshore
production platform
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Other locations to get regulatory information (See Web Links)
• BSEE (www.bsee.gov)
• American Petroleum Institute (api.org)
• E-CFR Code of Federal Regulations (www.ecfr.gov)
What’s it the primary purpose of the platform safety system information

found in API RP 14C?
The purpose of the platform’s safety system is to protect personnel, the environment, and
the facility from any adverse occurrences or undesirable events that will pose a threat to
safety.
What other information is provided in API RP 14C?
It also references safety devices used, their identification, system analysis of components,
protection concepts, as well as the location of safety devices on components.
How does it accomplish the basic protection task?
The task is accomplished by eliminating any inherent weakness in the process components
by providing two levels of protection (Primary and Secondary) that are functionally
different and independent of the normal control system.
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ASH - Analyzer Safety High (Combustible Gas Detector)
The ASH is an electrical device that provides continuous monitoring for the
accumulation of combustible gas vapors (in mixture with air), within
predetermined areas.
The ASH must be installed in specific locations as defined in Electrical Codes API RP 500 & 14F.
It must also be installed in all enclosed locations capable of reaching 25% of LEL (Lower
Explosive Limit) or LFL (Lower Flammable Limit).
A typical ASH operates in the following manner: Combustible gas vapors (in mixture with air)
enter into a porous sintered flame arrestor element. The combustible mixture comes in internal
contact with an active and a compensating detector element. Electronically, the detector
elements form part of a bridge circuit. A balance potentiometer is used to preset the output of
the bridge circuit to zero combustible gas. Only the active detector element will react to the
presence of the combustible gas vapors while the compensating element does not. In this
manner, the bridge circuit’s voltage output will change. This voltage change is conditioned by a
control transmitter to provide a linear output (Alarm Status indication).
As the combustible gas vapors dissipate (decreases below detection/control circuit reaction
levels), the detector sensor is returned to a zero combustible gas vapor environment. The
electronic bridge circuit regains to its balanced electrical condition or its return to the normal
operating status is re-established.
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Test Frequency Requirement:
The ASH must be tested every 3 months,
Alarm/Shut-in Requirements:
As the combustible gas vapor/air mixture increases to 25% of the LEL, the ASH must indicate
(yellow light indication) and alarm (audible sound provided throughout the platform).
At 60 % of the LEL, the ASH must shut-in the platform (additionally: audible sound
throughout the platform, red light indication, manual reset acknowledgement required).
Note: Some lessee’s choose to alarm, indicate and shut-in at levels lower than the maximums
listed previously (Example: The company may Alarm at 20% LEL and Shut-in at 50%).
This is an acceptable practice, however the BSEE (Bureau of Safety and Environmental
Enforcement (BSEE) mandated or published maximum levels should never be exceeded.
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BDV - Blow Down Valve

Blowdown Valves (BDV) is Normally Open, flow control valve assemblies that are most
commonly installed on Compressors and other process stations. They are used to quickly
depressurize specific process lines during an emergency or other necessary “blow-down”
operations (such as routine maintenance operations).
In its normal operating placement, the BDV has operating instrument supply pressure applied on
its pneumatic diaphragm assembly to maintain the closed-to-flow position. A Normally Open
Valve such as the BDV will automatically shift to the Open-to-Flow (Fail Open) status upon
loss of the operating power medium or operating instrument supply pressure.
An automatic BDV must be installed on the discharge line of all Compressors installations of
1,000 horsepower (746 Kilowatts) or greater.
BDV Test Frequency:
The BDV must be tested once every month (30 Days), not to exceed 42 days.
Tested for operation only.
Note: Blowdown Valves can be operated by either A. Pneumatic pressure operated, diaphragm
Actuators, B. Hydraulic pressure operated, Piston Actuators, C. Robot-Arm Actuators, D.
Electro-Mechanical Operator s.
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BSDV – Boarding Shut Down Valve NTL 2009-G36

The Barrier Concept involves the use of a boarding shut-down valve (BSDV), which assumes the
role of the surface safety valve (SSV) required by 30 CFR 250, Subpart H for a traditional dry tree
when associated with the Underwater Safety Valve (USV)
This ensures the maximum level of safety for the production facility and the people aboard the
facility. Because the BSDV becomes the most critical component of the subsea system, it is
necessary that this valve be subject to rigorous design and testing criteria
This valve is used in conjunction with the USV flow line incoming onto production processing
facility
Locate the BSDV within 10 feet of the first point of access to the boarding pipeline riser (i.e.,
within 10 feet of the edge of platform if the BSDV is horizontal, or within 10 feet above the first
accessible working deck, excluding the boat landing and above the splash zone, if the BSDV is
vertical).
Install a temperature safety element (TSE) and locate it within five 5 feet of each BSDV. Do not
use a resettable timer on the TSE associated with a BSDV.
Test the BSDV for leakage monthly, not to exceed 42 Days. If the monthly leak rate
test does not confirm zero leakage of the BSDV, shut in all sources to the BSDV and
repair or replace it before resuming production.
BSL - Burner Safety Low (Pilot Flame Failure detection device)
The Burner Safety Low (BSL) is a pilot flame failure detection devices typically used with natural
gas “fired” burner systems. They prevent the main burner assembly from coming on (opening-
to-flow) in case of pilot flame failure and thereby filling the fire tube with excess, explosive
natural gas vapors.
Some Burner Safety Lows are pneumatic safety devices (with internal 3 Way “Block & Bleed”
flow control assemblies) and a capillary, heat-sensing tube. In the pneumatic operated BSL, a
capillary tube is placed near the Pilot Light burner assembly (as depicted the next two drawings).
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As the pilot flame heats the expandable media enclosed within the capillary tube, it shifts the
internal flow control mechanism’s placement to establish pneumatic output pressure. In this
manner, the fuel SDV assembly, will open-to-flow as the normal operating sequence is achieved
and maintained.
The more modern BSL safety devices are electronic flame detectors that utilize the same
ultraviolet detection design concepts or characteristics used
by Ultraviolet Safety Highs (USH). Some BSLs may also utilize
a Flame Sensing Rod that is an electronic heat sensor element
for flame failure detection. These safety devices control the
Shutdown Valve’s operation electronically (Pilot Light on -
Fuel SDV open).
Capillary Tube Type – Pneumatic BSL:
• The pneumatic service BSL depicted has these

operating features or criteria:
• 2P (Two Position Movement – Internal components
move to either one of two placements)
• 3-W (Three-Way Internal Flow – Block & Bleed
assembly)
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• NC (Normally Closed-to-Flow – Shelf Position) it fails closed.

• TO (Temperature Operated – Achievement or gain of operating temperature moves
internal Micro switch components to Open-to-Flow placement).
• MR (Manual Reset – Knob must be rotated to Start placement after each Pilot Flame
Failure
BSL/TSL Test Frequency: The Burner Safety Low and Temperature Safety Lows safety device
should be tested once every year. Must Trip Within 45 Seconds
Note: A Temperature Safety Low (TSL) can also be used as a BSL.
CRBBM - Control Relay Block & Bleed Manual Reset

(Common “Trade” Name for Manual Reset Relays)
Manual Reset Relays (of the type shown below) are pneumatic, flow control, safety devices
designed with the following common control features: Two Position (2P) internal movement of
the flow control “spool” assembly, Three Way- Normally Closed (3W-NC “Block & Bleed”, flow
control port operation), Pilot Supply (PS) Pressure Operated, Spring Return (SR) and a Knob or
Palm Button for Manual Pull-Positioning operation (MR). Some models have a Latch or Lock-Out
Pin assembly mounted near the Knob for a “By-Pass” capability.
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A Manual Reset Relay should be thought of as an acknowledgement/ permissive tool. This

statement is defined next:
A.: Acknowledgement is the condition that the operator is aware of the safety sequence or
condition requiring manual reset action.
B.: Permission to achieve the next in-service status (pressurization of the receiving control
circuit to return to normal operation).
Manual Reset Relays like the below picture are commonly used on non-computer based safety
systems. When there is a safety sensor activation the bottom port will lose its supply pressure
causing the relay to shift. The Knob assembly must be pulled outward to allow instrument supply
pressure to transit the Inlet and Outlet flow control ports. There is a manual latch pin to
manually hold open the ports in operations position. Remember this is an Out Of Service
Status and must be flagged and monitored Once Pilot Supply pressure is reapplied at the
bottom port, the relay’s In-Service placement will be maintained. In this manner, critical
receiving control circuits and safety system devices maintain a pressurized status for normal
operation.
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CRBBM
Off The Shelf Mode
In Service Mode
Placed In By-Pass Mode

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ESD - Emergency Shut Down

The Emergency Shutdown System (ESD) stations are safety system control devices that allow
facility personnel to manually initiate a total platform shutdown whenever an abnormal
condition is observed. Manual control stations are strategically located throughout the platform
to initiate shutdown of all wells and process stations.
An ESD condition should result in the termination (stopping) of all sources of additional flow and
pressure from further entering the entire process facility. Activation of the ESD system shall
result in the closure of all wells to flow (both at the SCSSVs & SSVs), closure of all SDVs,
and opening of all BDVs.
ESD stations typically have one of the following design or operating features: pneumatic
pressure, hydraulic pressure, or electrically (Push Button or Lever Switch) operated. The
manually operated ESD valve(s) (that are pneumatic) shall be quick opening and non-restricted in
its flow capacity, to enable rapid actuation (exhaust) of the shutdown system.
ESD Station Test Frequency:
The ESD system should be tested once every month (30 Days, twelve times a year but not to
exceed 42 days). The test shall be conducted by alternating ESD stations monthly (to close at
least one wellhead SSV and verify a Surface-Controlled Subsurface Safety Valve closure for a
specific well as indicated by control circuitry actuation). Test time shall be 45 Seconds.
Notation: Only the ESD station at the boat landing may utilize a “loop” of breakable synthetic
tubing (Ploy flow plastic) in lieu of a standard valve assembly. The ferrules used within the
tubing connections of the ESD boat landing “loop” must also be manufactured from plastic. It
must be located close enough to the outside edge so the loop tubing can be allowed it to be
grasped and pulled (broken) free by the Boat “Hook.”
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Boat Landing ESD Loop
ESS - Emergency Support System

The Emergency Support System is comprised of the following: ESD, Fire Detection, Gas
Detection, Ventilation, Containment, Sumps, and Subsurface Safety Valve (SSSV) systems.
These individual systems provide a method of performing specific safety functions common to
the safety of entire process facility or platform.
Each individual system is essential to provide a specific level of protection to threats to safety, by
initiating shut-in functions or reacting in a manner that minimizes the consequences of released
hydrocarbons.
FA - Flame Arrestor
A Flame Arrestor is a flame-restricting, aluminum element core or cell (assembly) that prevents
the propagation of a flame or a flashback fire from exiting an enclosed area (generally a burner
firebox) to the outside atmosphere. It allows air for combustion to be drawn into the natural
draft burner assembly shown.
Flame Arrestors are designed to diffuse a potential combustible mixture over a broad surface
area to lower the contact ignition temperature substantially. The commonly utilized Flame
Arrestors have four (4) inch thick, aluminum element cores with very tightly spaced, .047”
diameter flow-hole orifices.
A Flame Arrestor functions to prevent flame/spark emissions from exiting a combustion

chamber and igniting a combustible source outside of a burn control area.
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A “T” type Flame Arrestor assembly is picture above. The “O”

is another style of Flame Arrestor assembly that is very
popular since it is much lighter in weight than the T type.
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FSH - Flow Safety High
FSL - Flow Safety Low

High flow is defined as flow above a predetermined or desired rate. The Flow Safety High safety
device monitors the flow rate and performs specific safety valve closure upon detection of
volume transfer above the predetermined or desired rate. High Flow most frequently occurs as
a result of flow restriction device failure. Examples are Choke (Positive or Adjustable) cutout of
trim and seat assemblies or enlargement of a restriction orifice due to sand erosion. Another
less frequent cause of High Flow is the accidental opening of a By-Pass Valve (BPV).
An electronic, Krohne manufactured Flow Transmitter assembly is depicted next. The

Transmitter’s electronic assembly can be programmed to perform both FSH & FSL function
applications.
FSH & FSL Test Frequency:
Both of these are tested once a year.
FSL: Low flow is defined as insufficient volume transfer or flow below a predetermined or
desired rate. The Flow Safety Low device monitors the flow rate and performs specific safety
valve closure upon detection of insufficient volume transfer. FSL sensors provide primary
protection mostly in fired vessels or exhaust heated components within which Excess
Temperature can occur. Some Flow Safety Low devices are designed to monitor air volume
transfer and others are designed strictly for fluid volume transfer.
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FSV - Flow Safety Valve (Check Valve)
• A FSV is a safety device that minimizes and prevents backflow.

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A Flow Safety Valve (Check Valve) is a control assembly that permits flow in only one outward
direction (from the inlet-to-outlet connection). It is also described as a device that minimizes or
prevents backflow of a flow stream.
Every process outlet shall have an FSV installed on it. For example: a three-phase production
Separator should have three (3) FSVs installed: One each on the Gas Outlet, Oil Outlet, and the
Water Outlet (connection).
The Flowline’s Flow Safety Valve should be tested for leakage once each month (not to
exceed 42 days). The FSV shall be tested in accordance with test procedures specified in API
14C.
Leakage Rate:
If the leakage measured exceeds a liquid flow of 200 cubic centimeters per minute (CCPM)
or a gas flow of 5 cubic feet per minute (CFM), the FSV shall be repaired or replaced.
FSV Test Frequency
The FSV is tested once a month (30 Days) (Wellhead Flow line Only) not to exceed 42 days
FTP - Flowing Tubing Pressure (on Wellhead) & SITP - Shut In Tubing Pressure
FTP - Flowing Tubing Pressure
Flowing Tubing Pressure (FTP) is described as the measurement of pressure of a well stream
flowing or operating under normal conditions or dynamic circumstances.
SITP - Shut In Tubing Pressure
Shut-In Tubing Pressure (SITP) is described as pressure that is indicated on the wellhead
Pressure Gauge (PG) whenever there is no flow or a static pressurized condition exits. It
represents the maximum pressure potential on a specific oil/gas well at the time of the pressure
test.
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(Crown Valve Pressure Gauge used to
to Operators) read SITP & FTP
Manually Operated Isolation
Valve
Adjustable
Flow Tee
OFFSHORE
(SDV)
(SSV)
Traditional two (2) Safety Valve Wellhead assembly: SSV in vertical run
and SDV downstream of Flow Tee in horizontal flow run.
Note: Manually Operated Isolation Valve ahead of each Safety Valve. 18
LEL - Lower Explosive Limit

The Lower Explosive Limit is the lowest concentration by volume (leanest or most minimal
content) of combustible vapors in mixture with air, which can be ignited at ambient conditions.
At the Lower Explosive Limit, the combustible vapor/air mixture can burn with only the most
minimal flame.
Federal Law Alarm/Shut-in Requirements:
As the combustible gas vapor/air mixture increases to maximum of 25% of the LEL, the
Analyzer Safety High (ASH) monitoring the enclosed area must indicate and alarm.
Calibration must be conducted quarterly (Every 90 Days)
UEL - Upper Explosive Limit

Upon detecting a maximum of 60% concentration of the LEL combustible gas vapor/air mixture,
the ASH must shut-in the platform. The ASH must additionally: audible sound throughout the
platform, red light indication, and a manual reset acknowledgement required).
Note: Some oil companies choose to alarm, indicate and shut-in at levels lower than the
maximums listed previously (Example: at 20% Alarm, Shut-in at 50%). This is an acceptable
practice, however the BSEE mandated or published maximum levels can never be exceeded.
The Upper Explosive Limit is the highest concentration by volume (richest or the most volatile
content) of combustible vapors in mixture with air, ignitable at ambient conditions. At the
Upper Explosive Limit, the combustible vapor/air mixture can burn with the most intense flame
and produce the highest BTU output possible (proportional to its molecular content).
Natural Gas becomes combustible at 5% gas in air

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LSH - Level Safety High
LSL - Level Safety Low

A Level Safety High (LSH) condition is defined as: An abnormal increase in the fluid level within
a process component, that rises above its normal operating limit or level. Many types of LSH
assemblies are utilized. The LSH & LSL assemblies can be pneumatic, two-way Normally Closed
“Bleed” or three-way Normally Open “Block & Bleed.” Some others are Discrete Electrical Level
Switches (On/Off) and the most modern ones are Digital Transmitters (Incremental/Proportional
Electronic output).
LSL - Level Safety Low:
A Level Safety Low condition is defined as: An abnormal decrease in the fluid level within a
process component, that falls below its normal operating limit or level. The same types of LSL
assemblies exist as the LSH controls described previously.
Note: Level Safety High assemblies depicted must always be tested

with a increasing fluid level.
Note: Level Safety Low assemblies depicted must always be tested

with a decreasing fluid level.
A Norriseal LSHL assembly is depicted next. The LSHL assembly is a

three-way, “Block & Bleed” type of Level Controller.
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LSH - Fisher Level Safety High
Fisher 2100, two-way “Bleed” type, pneumatic Level Safety High & Low are depicted.
The Fisher 2100 LSH has these operating features or criteria:
• 2P (Two Position Movement – Internal components move to either one of two

placements)
• 2-W (Two-Way Internal Flow – “Bleed” configuration).
• NC (Normally Closed-to-Flow – Shelf Position).
• LO (Level Operated – Raising or increasing Liquid or Fluid Level operates float “ball”
assembly).
• AR (Automatic Reset – Shifts the Flapper placement with each change of either high or
normal fluid level).
• LR (Level Return – Loss of high liquid level results in return to normal placement or a gain
of instrument supply pressure in receiving control circuit).
Shown above: Fisher 2100, two-way “Bleed” type, pneumatic Level Safety High &
Low are depicted above LSHL
Fisher Level Safety Low – LSL:
The Fisher 2100 LSL has these operating features or criteria:

placements)
• 2-W (Two-Way Internal Flow – “Bleed” configuration).
• NO (Normally Open-to-Flow – Shelf Position).
• LO (Level Operated – Falling or decreasing Liquid or Fluid Level operates float “ball”
assembly).
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• AR (Automatic Reset – Shifts the Flapper placement with each change of either low or
• LR (Level Return – Loss of normal liquid level results in establishing to open-to-flow
placement or a loss of output in the receiving control circuit).
Norriseal Level Safety High - LSH
The Norriseal LSH has these operating features or criteria:

placements)
• 3-W (Three-Way Internal Flow – “Block & Bleed”).
• NO (Normally Open-to-Flow – Shelf Position).
• LO (Level Operated – Raising or increasing Liquid or Fluid Level operates float “ball”
assembly).
• AR (Automatic Reset – Shifts the Stem placement with each change of either high or
• LR (Level Return – Loss of high liquid level results in return to normal placement or a gain
of instrument supply pressure in receiving control circuit).
Norriseal Level Safety Low:
The Norriseal LSL has these operating features or criteria:

placements)
• 3-W (Three-Way Internal Flow – “Block & Bleed”).
• NC (Normally Closed-to-Flow – Shelf Position).
• LO (Level Operated – Falling or decreasing Liquid or Fluid Level operates float “ball”
assembly).
• AR (Automatic Reset – Shifts the Stem placement with each change of either low or
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• LR (Level Return – Loss of liquid level results in return to abnormal placement or a loss of
instrument supply pressure in receiving control circuit).
Level Safety High & Level Safety Low (Pneumatic) assemblies shall be tested once every month,
not to exceed 42 days.
Level Safety High & Level Safety Low (Electronic) assemblies shall be tested once every
quarter, not to exceed 120 days
LSH – Level Safety High & LSL – Level Safety Low Symbols:
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MAOP - Maximum Allowable Operating Pressure (In a Pipeline)
BSEE Definition for Maximum Allowable Operating Pressure:
The highest operating pressure allowable at any point in a pipeline system during normal
operation (Flowing) or static conditions.
MAWP - Maximum Allowable Working Pressure
The Definition for Maximum Allowable Working Pressure is as follows: The highest allowable
working pressure at any point in any component, other than a pipeline during normal operation
or static conditions. The Maximum Allowable Working Pressure is a pressure safety factor to
insure safe operation of equipment or components.
It is the maximum pressure permissible in a process component (under any circumstance) during
normal operations within a specified temperature range. It is also known as the specific design
pressure limit that allows for safe operation of control devices and process equipment.
The MAWP is of critical importance since Pressure Safety Valve’s (PSV- Relief Valves) Pressure
Setting can never be set higher than the Maximum Allowable Working Pressure.
There is an exception: Completely redundant PSV (Relief Valves) Pressure Settings can be set
higher than the MAWP. The word “Redundant” means a duplicate or a second assembly (and in
some cases a third PSV) that is provided on larger production vessels as an extra safety
precaution.
This information is required to be placed on the ASME data code tag permanently affixed to a
pressurized component. If this data tag is missing the component has to placed OOS and gets
recertified as required
Process Component
A process component is a single piece of the production processing equipment used in a process
flow referred to which has the required safety devices installed
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OSH – Oxygen Safety High
Oxygen detector used for toxic services. OSHs used in example - H2S service
Testing frequency Requirement:
Testing and calibration once every two weeks (Bi-Weekly) on a production facility if H2S is
present, If used in a drilling or work over service then tested weekly.
PSH - Pressure Safety High
PSL - Pressure Safety Low
Pressure Safety High (PSH) function Pressure Sensors are utilized in typical safety systems to
initiate Safety Valve (SSV or SDV) closure, upon detection of abnormal high pressure. An
increase in monitored pressure above the Pressure Safety High Pressure Setting will result in a
loss of output (instrument supply) pressure to the receiving control circuit in which shuts down
that particular component. Shuts in or diverts the incoming flow through the closure of a
Shutdown Valve (SDV) or opening of a Blowdown Valve (BDV).
Axelson ESP Pilots
PSH Notation Items: A PSH control assembly is typically a primary detection and response
device. One exception is a in the “excessive combustible vapors in the firing chamber” process
condition, this situation employs the PSH assembly as a secondary detection and response
device.
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The PSH assembly should be tested with external pressure from one of the three following
sources: High-pressure natural gas available on the platform, Nitrogen (rack or bank of
pressurized cylinders) or hydraulic fluid (from either a “hand” pump (Enerpac) or specific
pneumatic pressure operated high pressure pump system (Haskell)).
Important: The PSH sensor should always be tested with a rising or increasing pressure
source.
PSL – Pressure Safety Low - A PSL control assembly is typically a primary detection device.
Note: One PSL function exception is in the “Underpressure” process condition. This undesirable
event situation employs the PSL assembly as a secondary detection and response device.
Gas Make Up is the primary protection for underpressure
The PSL sensor should always be tested with a falling or decreasing pressure source.
Important API PR 14C PSL Note
(For well flow-line segments in OCS facilities):
If any flow-line segment is longer (>) than 10 feet in length, another PSL is required.
PSHL - Pressure Safety High Low - (On Manifold Block)

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The PSHL (assembly) consist of individual PSH & PSL Pressure Sensors (Pilots) installed on a
common manifold (connection “block” or mounting bar) for convenient field installation.
The PSH & PSL Pressure Sensors connected in tandem (output of PSL is the input to the PSH as
shown) provides only one output signal to the First-Out Indicator or receiving control circuit.
PSHL Notation Items: A PSHL control assembly is typically a primary detection device.
Location: Pressure Sensors should be located at the highest point or in the gas vapor
section of a process component.
PSHL Test Frequency:
PSH, PSL or PSHL (Pneumatic) assemblies must be tested once every month, not to exceed
42 days.
PSH, PSL or PSHL (Electronic) assemblies must be tested once every quarter, not to exceed
120 days
The PSHL assembly should be tested with external pressure sources with a high enough pressure
to trip the high side from one of the three following sources: High-pressure natural gas available
on the platform, Nitrogen (rack or bank of pressurized cylinders) or hydraulic fluid (from either a
“hand” pump (Enerpac) or specific pneumatic pressure operated pump system (Haskell)). Never
use Oxygen bottles; this will cause a very violent reaction!!!
A Fisher 4160 “Bourdon Tube” (Left) and Axelson ESP (Right) PSHL Pressure Sensor’s internal
control components is depicted next.
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PSH – Pressure Safety High & PSL – Pressure Safety Low Symbols:
PSV - Pressure Safety Valve (Relief Valve)
Pressure Safety Valves (PSV) is designed to exhaust abnormal increasing pressure (the
valve’s internal parts will open-to-flow) as the component Pressure setting (normally the
MAWP) is achieved or surpassed. Upon detecting a decrease in monitored pressure, the PSV
internal parts return to a closed-to-flow position, Automatic Reset (once the component or
system pressure falls below the actual Pressure Setting). A PSV is typically a secondary
protection safety device that ensures the production system components or process
equipment will not overpressure.
An externally piloted or operated PSV assembly is depicted above.
PSV Notation Items: Qualified technicians only should repair the PSV. However, company
policy actually determines which personnel are qualified to perform field repairs of the PSV.
Note: The isolation valve located beneath the PSV must be a full ported, manual valve capable
of being locked in the open-to-flow placement during normal operation.
Leakage Rate Allowed:
Normally The PSV should never leak due to waste of natural gas into the atmosphere. Should an
ASME Coded PSV develop a leak, it is required either to repair with manufacture specified parts
or with an exact spare (from stock) that meets the same specifications, size, pressure installation
requirements.
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Pressure Discharge Notes: The outlet of the PSV must be installed and or piped to discharge or
relief pressure in a safe manner (or to a specific location), to avoid striking personnel and
prevent the creation of a hazard and any ignition sources.
Location & Testing:
Pressure Safety Valves should be located at the highest point or in the gas vapor section of
a process component. The PSV used in fluid service should be in the flow section.
The PSV should be tested once every year (Annual) as per BSEE and ASME requirements.
Some lessee’s require Bi-Annual testing
Pressure Safety Valve (PSV) Requirements
According to 30 CFR 250, Subpart H, Section 803 (i).
(i). Pressure relief valves shall be designed, installed and maintained in accordance with the
applicable provisions of sections I, IV and VIII of the ASME Boiler & Pressure Vessel Code. The
relief valve shall conform to the valve sizing and pressure-relieving requirements specified in
these documents; however, the relief valves, except completely redundant relief valves shall
be set no higher than the Maximum Allowable Working Pressure of the vessel.
Pressure Safety Element - PSE (Rupture Disk - Burst

Plate)
Vacuum/Pressure Relief for Atmospheric Rated Vessels (up to 5 PSIG)

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Qualified Person
An individual with characteristics or abilities gained through training and or experience or both,
as measured against established requirements such as standards or tests, and that enable the
individual to perform a required function.
SAC Chart - Safety Analysis Checklist
The Safety Analysis Checklist is a reference of ten (10) specific, process component item “tables”
that list all normally utilized safety system control devices that should be utilized to protect each
individual process component (as listed).
The SAC Reference List has a directory (individual item list) of all safety devices required to
protect each process component from the worst possible input and output conditions. Also
listed under each safety device items are certain (specific) conditions that allow for the omission
(or elimination) of particular safety devices (as listed). This action is justified since safety devices
(or engineering design features) on other process components will provide the same level of
protection or in a specific configuration, the abnormal condition detected will not lead to a
threat to safety.
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Simply Stated: All of the safety devices listed within the SAC Table Reference List should be
installed on the individual process components (as detailed within each item Table) unless there
is specific justification for their omission. The SAC Reference List and SAFE Chart are used as
basic tools for developing a platform’s complete safety system based upon the level of
protection required by the process components and the requirements of the Emergency
Support Systems (ESS). Once the SAC Reference’s safety device listing has been fully complied
and documented, the facilities SAFE Chart is then developed next.
SAFE - Safety Analysis Function Evaluation (Chart)
The Safety Analysis Function Evaluation (SAFE) Chart (for a specific process facility) is used to
relate all safety sensing devices, SDVs (BDVs, etc.), Shutdown devices (including ESD) and
Emergency Support Systems to their functions (in a chart matrix format). The SAFE chart list all
process components and Emergency Support Systems with their required safety devices and the
function to be performed by each device. If the safety device is not needed (if it can be omitted
as determined in the SAC Reference List Tables) the reason shall be listed in the SAFE Chart
format matrix by referring to the appropriate SAC Item number. The relationship of each safety
device with its required function can be documented (and verified) by checking the appropriate
“box” in the chart matrix. Completion of the SAFE Chart provides the safety system designers,
platform personnel and BSEE inspectors with a means of verifying correct design logic of the
facilities’ basic safety system.
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SAT - Safety Analysis Table
The Safety Analysis Table highlights (lists) the eight Undesirable Events (effects of equipment
failures, process upset, accidents, etc. in relation to process components) from which protection
should be provided, along with the detectable conditions that could be monitored for safety
surveillance. These detectable conditions (listed within the SAT) are used to initiate action
through automatic controls to prevent or minimize the effects of undesirable events. The SAT
also presents the logical sequence of safety system development, including Undesirable Events
that could be created in downstream process components because of failures in the equipment
or safety devices of the component under consideration.
The Safety Analysis Tables (SAT) is somewhat similar to the SAC Reference Listing except its
primary focus is upon Undesirable Events and their causes. The generic cause of each
Undesirable Event is listed within the Safety Analysis Tables.
SCSSV – Surface Control SubSurface Safety Valve
SCSSV - Surface Control Subsurface Safety Valve (Principal or most common type of SSSV)
Is a two position (2P), two-way Normally Closed (2W-NC that fails closed-to-flow upon loss of
operating hydraulic fluid pressure) safety valve assembly. When an abnormal condition such
as ESD activation, TSE activation, or Fire on the surface facility is detected (that requires a total
facility shut-in), operating hydraulic pressure to the SCSSV is exhausted by a wellhead control
panel. A loss of operating hydraulic pressure closes the SCSSV to internal flow.
The purpose of the Surface Control Subsurface Safety Valve (SCSSV) is to prevent the oil/gas
well from flowing in an uncontrollable manner, if the wellhead should become separated from
the Production Tubing and Casing Head assembly. Separation of the surface equipment can
happen due to an explosion at the surface facility, ramming of the wellhead by a large ship or an
accidental blow-out. The SCSSV is a certified valve and requires certification documentation
when installed
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Operating Sequence Required:
The normal Open/Close operating sequence of the SCSSV is described next:
A. Opening Sequence: SCSSV Opens First; Stabilize well then open the SSV Open Second
B. Closing sequence: SSV closes first (within 45 seconds); SCSSV closes second (within two
minutes of last SSV closure).
Location & Installation:
All Subsurface Safety Valves such as the SCSSV and SSCSSV shall be located 100 feet or more
below the mud line or seabed floor. The SCSSV must be installed within the Production Tubing
within two days after production is established.
Leakage Allowance:
The SCSSV has a 200 CC Liquid or 5 Cubic Feet Gas per Minute leakage tolerance during
testing.
Required Testing Frequency:
The SCSSV should be tested once every six months (bi-annual)

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A SCSSV simple schematic drawing is provided next to depict the basic hydraulic safety system
and SCSSV control assembly.
SSCSV - Sub Surface Control Safety Valve (one type of SSSV)
Also Called a Storm Choke in laymen’s term
The Sub Surface Control Safety Valve (SSCSV) is an equivalent to the SCSSV except the “down-
hole” SSSV is operated (closed) by flow characteristics (abnormal subsurface internal
pressure and flow) of the well stream. Flow characteristics in this case, is described as the
development of an abnormal differential pressure flow (a high flow velocity) through the central
bore or internal components of the SSCSV. The abnormal flow is caused by a loss of the well
head valve assemblies or high, uncontrolled flow due to severe malfunction in the surface
equipment (that normally regulates or restricts the flow within the well bore). Once the SSCSV
has been closed-to-flow, equalizing control pressure must be applied within the production
tubing (on top of the SSCSV through a control panel) to enable the full pressure equalization
process to reopen the valve assembly to internal flow.
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Required Testing Frequency:
The SSCSV has two circumstances for its testing frequency requirements. The test frequency is
detailed as follows:
A. Test once every year if the SSCSV is installed in

a Landing Nipple. A Landing Nipple is essentially an
outer protective “sleeve” assembly, that prevents
movement or displacement of the SSCSV assembly (since
it is acted upon by abnormal high-pressure flow) from
within the Production Tubing.
B. Test every six months if the SSCSV is not installed

in a Landing Nipple.
Leakage Allowance: The SSCSV has a 200 CC Liquid or

5 Cubic Feet Gas per Minute leakage tolerance during
testing.
This valve is installed only when the SCSSV has failed and
cannot be repaired. The SSCSV is a certified valve and
requires documentation when installed
The landing nipple should also have certifications

documents on file.
The SSCSSV is also known as a Storm choke.
SSCSSV PB SSSV
The wireline retrievable type sub surface safety valve PB Safety Valve (PB = Pressure Balance) is
set for a predetermined flow rate. PB safety valves are wireline‑retrievable, poppet-type,
subsurface-controlled subsurface safety valves, that is tubing-pressure sensitive and can
be adjusted to close at a pre-set tubing pressure. If a flow characteristics or flow rat
greater than the set maximum rate is encountered, the safety valve will close.
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SDV – Shut Down Valve

The Shut Down Valve is an automatically operated, Normally Closed, flow control valve
assembly that is installed on process equipment to quickly shut off the source of inlet pressure
or flow during an emergency or upon the detection of an abnormality. A Normally Closed Valve
such as the SDV will automatically shift to the Closed-to-Flow status upon loss of the power
operating medium or instrument supply pressure. Most SDVs rely upon a large internal spring to
shift the components to a fail-closed position. Shutdown Valves can be operated by pressure or
power from one of the following sources: pneumatic diaphragm, hydraulic piston, robot-arm
actuator or an electric motor.
Leakage Allowance: The SDV on the FA-1 flowline has a 200 CC Liquid or 5 Cubic Feet Gas per
Minute leakage tolerance. The other SV’s are tested only for operational ability.
Required Testing Frequency: The SDV shall be tested once every month (not to exceed 42
days) for operational ability
An N.P.T. (Pipe Thread or Screwed Connection Body) type, isolation purpose,

pneumatic diaphragm operated assembly SDV (primarily used on smaller process
units) is depicted next.
Note: Shutdown Valves can be operated by either A. Pneumatic pressure operated, diaphragm
Actuators, B. Hydraulic pressure operated, Piston Actuators, C. Robot-Arm Actuators, D.
Electro-Mechanical Operators.
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SSV - Surface Safety Valve

The Surface Safety Valve (SSV) is an automatically operated, Normally Closed (fails in the
closed-to-flow placement), safety valve located on the wellhead assembly. It is the second valve
in the vertical “run” (located directly above the bottom Master Valve). The SSV can be operated
only by either pneumatic (diaphragm) or hydraulic (piston) pressure.
The normal Open/Close, operating sequence of the SSV is described next.
A. Opening sequence: SCSSV Opens First; SSV Opens Second.
B. Closing sequence: SSV closes first (within 45 seconds of ESD, TSE, Safe Chart actuation);
SCSSV closes second (within two minutes of SSV closure).
Only certified and qualified technicians can repair the SSV. Only Certified parts may be used in
the repair the SSV Valve. The SSV certification documents must be kept on file at the platform or
field office.
Leakage Allowance: the SSV has a zero (“O” or no) leakage tolerance.
Required Testing Frequency: Test once every month, not to exceed 42 days.
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TSE - Temperature Safety Element (Fusible Plug) API RP 14C Table C-1
Temperature Safety Elements are special connection devices that have one end sealed with
eutectic material (in solid form). TSE are also commonly known as Fusible Plugs and are
generally either N.P.T (screwed connection), Filled Tubing Cap (Solid Plug Ferrule) or “Tube
Stub” insertion type components. Temperature Safety Elements with a sealed end (of solid
“plug” eutectic material similar to common lead) allows the corresponding pneumatic ESD
system to remain continuously pressurized for normal operation. Once the TSE (Fusible Plug)
assembly is subjected to intense heat or a flame source (attaining the specific temperature
rating of the installed TSE), the eutectic material melts and is exhausted from its pressurized
connection. In this manner, the pneumatic ESD system is depressurized to begin the emergency
response shutdown sequence. A total platform shutdown will result upon the detection of a
fire.
Temperature Safety Elements generally have their specific temperature rating imprinted on the
external surface and many are additionally color coded for easy recognition.
A Solid Plug Ferrule, Tubing “Cap” type, TSE is shown next.
“Tube Stub”, insertion type TSE (Fusible Plugs) are shown installed on the Line Heater’s “Fire”
Loop depicted above. All BSEE districts require TSE tested annually but according to
requirements of 30 CFR 250.804 (a)(9) “ all fire (Flame, Heat, Smoke) detection systems shall be
tested for operation every three months provided that testing can be performed in a non-
destructive manner.
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TSH - Temperature Safety High

Pneumatic Temperature Controllers, electrical sensors and electronic transmitters can all
employed as Temperature Safety High, safety devices on heated process components utilized
within production facilities. The purpose of the TSH is to detect and respond to an abnormal
temperature increase above a specific temperature setting. Drawings of four types of
temperature controllers will be provided.
A cross section assembly view and an isometric projection drawing of a pneumatic, NPT
connection, Kimray model, Temperature Controller (utilized as a TSH) is depicted next. Note the
Thermowell assembly shown. The Temperature Controller must always be inserted in the
Thermowell (that is installed in process vessel or component with the hot fluid media contained
within).
Kimray Models
The type of Temperature Controller depicted above, uses the thermal expansion differences
that occurs within two different metals (whenever they are heated) to produce mechanical
movement within an internal, pneumatic flow control assembly. The application of heat (that
increases above the temperature setting and its detection) will result in a loss of output
pressure to the receiving control device. The movement or expansion of the metals is
proportional to temperature changes. In this manner, the receiving control circuit experiences a
loss of operating pressure upon detecting and responding to a Temperature Safety High
condition
A typical electrical thermocouple type, used in electronic systems, the temperature sensor is
detected next.
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An analog type Temperature Transmitter that provides the TSH, TSL or TSHL programmed
functions (associated with PLC, electronic safety systems) is shown next.
A very popular nondestructive TSH used is the Ex-Line pictured below
TSH & TSL Required Test Frequency:
The TSH & TSL are tested once every year (Annual). The TSH must always be tested with an
increasing temperature and the TSL must be tested with decreasing temperature.
Note: A TSH that is installed on a Compressor must be tested every six (6) months.
The TSH commonly utilized on Compressors is shown next.
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USH - Ultraviolet Safety High (Flame Detector / Sensor)

The Ultraviolet Safety High (Flame Detector) is a discrete type, electrical component that
provides continuous monitoring for the detection of a flame or fire within predetermined
control areas. Flame Detectors must be installed in specific locations as defined in Electrical
Codes API RP 500 & API RP 14F.
A typical USH operates by detecting the ultraviolet radiation emitted by combustion flames (fire
and also lightning, reflected sunlight, etc.). An electrical control transmitter is used to provide a
linear output (Alarm “On” status or indication). As the ultraviolet spectrum level returns to
normal, the USH detector sensor regains to its balanced electrical condition or normal operating
status (Alarm “Off” status).
A photograph of a wall mounted Ultraviolet Safety High (USH - Flame Detector) is provided next.
Required Test Frequency: The Ultraviolet Safety High (USH) should be tested once every
three months (quarterly).
Notes: If a “flame safeguard” type USH (“Purple Peeper” etc. as they are commonly known in the
industry), is being utilized as a BSL, testing is required only once a year.
The USH is often installed in “cross zone or cross ported” detection areas. In other words: The
lenses of two separate USH assemblies are directed to view the same area but they are installed
at points or locations across or opposite form one another. The two USH assemblies must
detect or view the same source of emitted ultraviolet radiation, independently of one another.
This method of double detection prevents sunlight, reflections, lightning, etc. from causing
nuisance ESD Shut-ins.
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USV - Underwater Safety Valve

The Underwater Safety Valve (USV as its name suggest) is underwater version of the SSV. On
sub-sea completions, the USV is generally located in a horizontal “run” of the Wellhead piping.
For all practical purposes, the USV assembly operates in much the manner as the SSV does.
However the physical appearances and structure of the USV and SSV are different.
Required Test Frequency:
Test once every quarter (90 Days), not to exceed 120 days except when in operation under the
NTL 2009-36
Leakage Allowance:
The USV has a 400 CC Liquid or 15 Cubic Feet Gas per Minute leakage tolerance Test Duration
Minimum of five (5) Minutes when utilizing a (BSDV) underwater incoming boarding valve
otherwise which has a (0) Zero Leakage Tolerance in lieu of the USV monthly test which
then becomes quarterly. The USV has a zero leakage tolerance and test schedule 30 CFR
250.804 (5) (Appendix 8) but can use alternate procedures as per NTL 2009-36, 30 CFR
250.292(o) (DWOP) Deepwater Ops Plan will list these alternate compliance procedures
NTL 2009-G36 Appendix D: Valve Closure Testing
Valve Allowable Leakage Rate Testing Frequency

BSDV Zero Leakage Monthly, not to exceed 6 weeks
Electronic E SD Logic N/A Monthly, not to exceed 6 weeks
Electronic ESD Function N/A Quarterly, not to exceed 120 day
USV1
USV2 N/A1 N/A1
USV Leakage Rate: - 400 cc per minute of liquid or 15 scf per minute of gas
Test Schedule: Quarterly, not to exceed 120 days
SCSSV
- Leakage Rate: - 400 cc per minute of liquid or 15 scf per minute of gas
- Test Schedule Semiannually, not to exceed 6 calendar months
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YSH - Ionization Safety High (Smoke Detector)

The Ionization Safety High (YSH - Smoke Detector) is a discrete type, electrical device that is
designed for the continuous monitoring of smoke accumulation within predetermined control
areas. It is installed in specific locations as defined in Electrical Codes API RP 500 & API RP 14F.
A typical YSH (Smoke Detector) is pictured next.
A standard YSH (ionization type) operates as follows: Smoke enters the assembly through the
sensor probe inlet. A small amount of radioactive material is used to ionize the air (by adding or
removing electrons from the air within). A small electrical current is generated across the
ionized air particles. The presence of smoke within the probe inlet will interfere with the flow of
ionized air particles to decrease the electrical current generated. The current change is
conditioned by a control transmitter to provide a linear output (Alarm status “On” or indication).
As the smoke-free, air content level returns to normal, the YSH detector sensor regains to its
balanced electrical condition or normal operating status (Alarm status “OFF”).
Required Test Frequency:

The YSH should be tested once every three months (90 Days) (quarterly).
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SAFETY DEVICE SYMBOLS & IDENTIFICATION

Introduction
A standard method for identifying, abbreviation, and symbolizing individual safety devices is
needed to promote uniformity when describing or referring to safety systems components. This
method can be used to illustrate safety devices on flow diagrams and other drawings, and to
identify an individual safety device for any purpose.
Abbreviations and symbols recommended are derived insofar as possible, from Instrument
Society of America (ISA) Standard ISA-S5.1. Additional applications that adhere to this standard
may be derived as required. However, certain abbreviations have such wide oil field acceptance
that their continued use is justified even though they do not strictly conform to the ISA
standard. The abbreviations SSV for Surface Safety Valve and ESD for Emergency Shutdown,
are examples.
Functional Device Identification
Each safety device should be identified by a system of letters used to classify it functionally. The
functional identification includes one first letter covering the measured or initiating variable and
one or more succeeding letters covering the function of the device. The term “Safety” (S) shall
apply to emergency protective elements and is used as the second letter of sensing and self-
acting devices.
Note the four process variables in the left column, safety and the various function or
element in the right side column.
Pressure High
Level Low
Safety
Temperature Element
Flow Valve
Safety Device Symbols (Circular Balloon Tags)
The circular balloon is used to tag distinctive symbols, such as a Pressure Safety High (PSH - High
Pressure Sensor) for example. In such instances, the line connecting the balloon to the
instrument symbol is drawn close to, but not touching, the symbol.
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Two safety devices for related or associated process variables may be placed within the same
balloon symbol as depicted next. Example (PSHL)
Symbol Identification Note:
If two or more devices of the same type are installed on a single component, each device should
be numbered consecutively and the number shown following the functional identification.
Example for Two or More of the Same Device: FSV1 (Oil), FSV2 (Water), FSV3 (GAS) & LSL1 (Oil)
& LSL2 (Water).
If only one device is installed, the device number may be omitted.

Single Safety Device Lettering example: LSH (as shown first)
In other instances, the balloon serves to represent the device proper (dashed circle
that indicates the device is omitted (SAC’d out)from installation).
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Balloon Symbols without the tag line “tails” are safety devices that are not hard
piped to process vessels or components. They are installed in a general area. Note
the Temperature Safety Element (TSE) is installed or attached to instrument
tubing and the Analyzer Safety High (ASH) is attached to conduit (electrical) piping
or explosion proof cable.
This symbol with no tail shows the safety device is installed but in a general
location.
The illustrations as provided, depicts various (recommended) example symbols

utilized industry wide.
Sensing and Self-Acting Device

Safety Device Designation Symbol
Instrument
Combination
Variable Common Name Society of Single Device
Device
America (ISA)
Flow
Backflow Check Valve Safety
Valve
Burner
Burner Flame
Burner Flame Safety
Detector
Low
Flow
High Flow Sensor Safety
High
Flow
Flow
Low Flow Sensor Safety
Low
Level
High Level Sensor Safety
High
Level
Level
Low Level Sensor Safety
Low
Pressure Safety
Pressure High Pressure Sensor
High
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Pressure Safety
Low Pressure Sensor
Low
Pressure Relief or Pressure Safety

Safety Valve Valve
Rupture Disc or Pressure Safety

Safety Head Element
Pressure-Vacuum Pressure Safety

Relief Valve Valve
Pressure or Pressure-Vacuum Pressure Safety 1.

Vacuum Relief Manhole Cover Valve
Vent None
Pressure Safety
Vacuum Relief Valve
Valve
Vacuum
Rupture Disc or Pressure Safety
Safety Head Element
Temperature
High Temperature
Safety
Sensor
High
Temperature
Temperature
Low Temperature
Safety
Sensor
Low
Flame or Stack Flame Arrestor
Flame
Arrestor Stack Arrestor
Ultraviolet
Flame Detector
Safety
(Ultraviolet/Infrared)
High
Temperature
Heat Detector 2.
Safety
(Thermal)
Fire High
Ionization (Y)
Smoke Detector
Safety
(Ionization) 3.
High
Fusible Material Temperature
(Plug) Safety Element
Combustible
Combustible Gas Analyzer Safety
Gas
Detector High
Concentration
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Oxygen
Toxic Gas
Toxic Gas Detector Safety
Concentration
High
Actuated Valves
Service Common Symbols
Wellhead
"USV" for
Surface Safety
Underwater
Valve or
Safety
Underwater
Valve
Safety Valve
Blowdown
Valve
Shutdown
Valves
Notes:
1. The Surface Safety Valve (SSV) can be operated by either a Hydraulic Piston
Actuator or a Pneumatic Pressure operated Actuator.
2. Blowdown Valves (BDV) & Shutdown Valves (SDV) can be operated by any of
the four following controller or operating methods:
(A.) Hydraulic Piston Actuator,
(B.) Pneumatic Pressure operated Actuator,
(C.) Robot Arm Actuator,
(D.) Electro/Mechanical Motor.
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Component Identification
(Lettering System for Process Vessels & Associated Equipment)
Introduction
The complete identification of a safety device includes reference to the component that it
protects. This is accomplished by following the device functional identification or device number
(if applicable) with a component identification.
The table listing on the next page presents the recommended component identification method.
The first letter is the component type and it (the letter) must be one of the letters in the Code
column under component type. The letter “Z” is used to cover a component that is not listed. It
performs some type of function not listed in the table.
The second and third letters may be used to further define or otherwise modify the first
character. If a modifier is not used the character “o” should be shown in lieu of the modifier.
The last four characters or numbers identify the specific component. These characters are user
assigned and must be unique to the component at the particular location (specific facility).
Process Vessel example: MBD 1000. Identify the component from the example provided by
using the Component Identification table provided on the next page.
M for Pressure Vessel (Ambient Temperature – Not Heated)

BD for Separator
1000 typically for first vessel in process series or production “train”.
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Component Identification
(Lettering System for Process Components)
First Second Succeeding

Letter Letter Characters
X XX XXXX
Component Component Component

Type Modifier Identifier
COMMON
CODE COMPONENT MODIFIERS CODE COMPONENT
A ATMOSPHERIC VESSEL BH, BJ, BM AA BI-DIRECTIONAL User Assigned
(AMBIENT TEMPERATURE) Identification Unique
B ATMOSPHERIC VESSEL AP,BC,BK,BM AB BLOWCASE to Equipment at Local
(HEATED)
C COMPRESSOR NONE AC BOILER
D ENCLOSURE AE,AN,AU,BB AD COALESCER
E FIRED OR EXHAUST AL,AW,BN AE COMPRESSOR
HEATED COMPONENT
F FLOWLINE A1-A9 AF CONTRACTOR
G HEADER AR,AS,AT,AY,AZ AG CONTROL UNIT
H HEAT EXCHANGER BG AH DEPARTING
J INJECTION LINE AR,AS,AT,AJ FILTER
K PIPELINE AA,AH,AQ AK FILTER-SEPARATOR
L PLATFORM AG AL FORCED DRAFT
M PRESSURE VESSEL AB,AD,AF,AJ,AK,AM AM FREEWATER KNOCKOUT
(AMBIENT TEMPERATURE) AV,BD,BF,BH,BJ,BL,BM
N PRESSURE VESSEL AC,AF,AM,AP,BC,BD AN GENERATOR
(HEATED) BG,BJ,BK
P PUMP AX,BA,BE AP HEATER
Q WELLHEAD AR,AT,AY,AZ AQ INCOMING
Z OTHER AR INJECTION, GAS
AS INJECTION, GAS LIFT
AT INJECTION, WATER
AU METER
AV METERING VESSEL
AW NATURAL DRAFT
AX PIPELINE
AY PRODUCTION, HYDROCARBON
AZ PRODUCTION, WATER
A1-A9 FLOWLINE SEGMENT
BA PROCESS, OTHER
BB PUMP
BC REBOILER
BD SEPARATOR
BE SERVICE
BF SCRUBBER
BG SHELL AND TUBE
BH SUMP
BJ TANK
BK TREATER
BL VOLUME BOTTLE
BM WATER TREATING
BN EXHAUST HEATED
ZZ OTHER
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Abbreviations
ASH - Analyzer Safety High

BDV Blow Down Valve
BSDV - Boarding Shut Down
Valve
BSL - Burner Safety Low
CRBBM - Control Relay Block and Bleed W/Manual Reset
ESD - Emergency Shutdown
FA - Flame Arrestor Pressure High
FSH - Flow Safety High Level Low
FSL - Flow Safety Low Safety
FSV - Flow Safety Valve Temperature Element
FTP - Flowing Tubing Pressure Flow Valve
LEL - Lower Explosive Limit
MAOP - Maximum Allowable Operating Pressure (Pipelines)
MAWP - Maximum Allowable Working Pressure (All Else)
OSH - Oxygen Safety High
PSE - Pressure Safety Element Process Variables (4)
PSH - Pressure Safety High Pressure Temperature
PSL - Pressure Safety Low Level Flow
PSV - Pressure Safety Valve
SA - Stack Arrestor
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SAC - Safety Analysis Checklist

SAFE - Safety Analysis Function Evaluation
SAT - Safety Analysis Table
SCSSV - Surface Control Subsurface Safety Valve
SDV - Shut Down Valve
SITP - Shut In Tubing Pressure
SSCSV - Sub Surface Control Subsurface Safety Valve
SSSV - Sub Surface Safety Valve
(8) Eight Undesirable Events

1.Overpressure
SSV - Surface Safety Valve 2. Underpressure
TSE - Temperature Safety Element 3. Leak
TSH - Temperature Safety High 4. Liquid Overflow
UEL - Upper Explosive Limit 5. Gas Blowby
USH - Ultraviolet Safety High 6. Excessive Temperature
USV - Underwater Safety Valve 7. Ignition Source
YSH - Ionization Safety High 8. Excess Vapors in Fire
Tube
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Subpart-O
(PSST)
Training
Module
2
Process Variables, Undesirable Events,
Primary & Secondary Protection
& Definitions
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Process Variables (4)

There are FOUR (4) process variables that normally affect every process component in the oil
and gas industry (in one combination or another). The four process variables are listed next:
Pressure, Level, Temperature, Flow
Pressure, Level, Temperature and Flow are the only variables that can range either normal or
abnormal (outside of operating ranges, limits or operating parameters) within production
equipment or process components.
If standard controls and Safety Sensors fail, an Undesirable Event will occur.
Undesirable Events (8)

UNDESIRABLE EVENT – An ADVERSE OCCURRENCE in a process component which poses a
threat to safety.
The Undesirable Events discussed in this paragraph are those that might develop in a process
component under worst-case conditions of input and output.
An Undesirable Event may be indicated by one or more process variables ranging out-of-normal
operating limits.
These abnormal operating conditions can be detected by Safety Sensors that initiate shut down
action to protect the process component.
Each undesirable event that can affect a process component is discussed according to the
following format: (a) cause, (b) effect and detectable abnormal condition, and (c) Primary and
Secondary protection that should prevent or react to its occurrence.
There are EIGHT (8) UNDESIRABLE EVENTS. They are listed as follows:
1) Overpressure
2) Underpressure
3) Leak
4) Liquid Overflow
5) Gas Blow by
6) Excess Temperature
7) Ignition Source
8) Excess Vapors in a Fire tube
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Primary and Secondary protection for the prevention of an occurrence of one or more of the
eight (8) undesirable events are provided by sensors or safety devices as follows.
OVERPRESSURE
OVERPRESSURE is pressure in a process component in excess of the MAWP or MAOP.
OVERPRESSURE occurs whenever inflow exceeds outflow.
Secondary Protection: Secondary protection from overpressure in a pressure component

should be provided by PSV. Secondary protection for atmospheric components should be
provided by a second vent. The second vent may be identical to the primary vent, a gauge hatch
with a self-contained PSV or an independent PSV.
Detectable Abnormal Secondary

Primary Protection
Conditions Protection
Overpressure
Pressured Vessel PSH PSV
Atmospheric Vessel Vent Second Vent: PSV
PSH Occurrence - the occurrence of a PSH (or any other Safety Sensor’s detection of a fault or
abnormality) should always result in the inlet source of pressure and flow being shut-in or
diverted.
Causes: Overpressure can be caused by an input source that will develop pressure in excess of a
process component’s maximum allowable working pressure (MAWP) if inflow exceeds outflow.
Inflow exceeds outflow if an upstream flow rate control device fails, if there are restrictions or
blockage in the component’s outlets, or if overflow or gas blow-by from an upstream component
occurs. Overpressure can also be caused by thermal expansion of fluids within a component if
heat is added while the inlets and outlets are closed.
Effect and Detectable Abnormal Conditions: The effect of overpressure can be sudden
rupture and leak of hydrocarbons. High pressure is the detectable abnormal condition that
indicates that overpressure may occur.
Location of Safety Devices: In the process component with a liquid and a gas section, the PSH
sensor, PSV or vent should be installed to sense or relieve pressure from the gas or vapor
section. The sensing connections for and safety devices should be located at the highest
practical location on the component to minimize the chance of fouling by flow stream
contaminants.
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UNDERPRESSURE
UNDERPRESSURE is pressure in a process component less than the design collapse pressure.
UNDERPRESSURE occurs whenever outflow exceeds inflow.
Three (3) conditions that could cause UNDERPRESSURE:
1. Whenever control valves fail

2. Thermal contraction in isolated vessels occurs
3. Blockage of inlet during withdrawal
Primary Protection: Primary protection from under-pressure in an atmospheric component

should be provided by an adequate vent system. Primary protection for the pressure
component subject to under-pressure should be provided by a gas makeup system.
Secondary Protection: Secondary protection for an atmospheric component should be

provided by a second vent or by a PSV. Secondary protection for a pressure component subject
to under-pressure should be provided by a PSL sensor to shut off inflow and outflow.

Primary Protection
Underpressure
Pressured Vessel Gas Makeup PSL
Atmospheric Vessel Vent PSV/Vent
Cause: Under-pressure can be caused (A) by fluid withdrawal in excess of inflow that may be the
result of failure of an inlet or outlet control valve, (B) blockage of an inlet line during withdrawal,
or (C) thermal contraction of fluids when the inlets and outlets are closed.
Effect and Detectable Abnormal Conditions: The effect of under-pressure can be collapse of
the component and a leak. Low pressure is the detectable abnormal condition that indicates
under-pressure may occur.
Location of Safety Devices: The PSL sensor should be installed at the highest practical location
on the component to minimize the chances of fouling by flow steam contaminants.
Gas Makeup Regulators:
Primary protection for under pressure in a pressure vessel is Gas Makeup.

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LEAK
LEAK is the accidental escape of fluids from a process component to atmosphere.
A leak implies that the escaping fluids are hydrocarbons. A leak can occur whenever a flow-line
or pipe section breaks.
Primary Protection: Primary protection from leaks of sufficient rate to create an abnormal
operating condition within a pressure component should be provided by a PSL sensor to shut off
inflow and a FSV to minimize backflow. Primary protection from leaks from the liquid section
may also be provided by an LSL sensor to shut off inflow. On an atmospheric component,
primary protection from small liquid leaks should be provided by an LSL sensor to shut off
inflow. A Containment system should provide primary protection from a small liquid leaks that
cannot be detected by the safety devices on a process component. Primary protection form
small gas leaks that occur in an inadequately ventilated area and cannot be detected by
component sensing devices should be provided by a combustible gas detection system.
Secondary Protection: Secondary protection from all detectable leaks and small gas leaks in an
inadequately ventilated area should be provided by the Emergency Support Systems (ESS).
Secondary protection from small liquid leaks should be provided by a LSH Sensor installed on the
sump tank to shut in all components that could leak into the sump.

Primary Protection
Leak
Large Leak Pressured Vessel PSL, FSV, LSL ESS
Atmospheric Vessel LSL ESS
Small Leak Gas ASH ESS
Containment
Small Leak Liquid LSH on Sump
(Skid or drip pan)
Flow Safety Valves (FSVs) are installed on the outlets of all process vessels to minimize or
prevent backflow.
Each process outlet line (Oil, Gas, Produced Water) shall have a FSV installed.
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Cause: A leak can be caused by deterioration from corrosion, erosion, mechanical failure, or
excess temperature; by rupture from overpressure; or by accidental damage from external
forces.
Effect and Detectable Abnormal Conditions: The effect of a leak is the release of
hydrocarbons to the atmosphere. Low pressure, backflow, and low level are the abnormal
conditions that might be detectable to indicate that a leak has occurred.
Location of Safety Devices: In a process component with both a liquid and a gas section, the
PSL sensor should be connected to sense pressure from the gas or vapor section. The PSL
sensor should be installed at the highest practical location on the component to minimize the
chances of fouling by flow stream contaminants.
FSVs should be installed in each component operating outlet line subject to significant backflow.
The LSL sensor should be located a sufficient distance below the lowest operating liquid level to
avoid nuisance shutdowns, but with adequate volume between the LSL sensor and liquid outlet
to prevent gas blow-by before shutdown is accomplished.
LIQUID OVERFLOW
LIQUID OVERFLOW is the discharge of liquid from a process component through a gas outlet.
LIQUID OVERFLOW occurs whenever a Liquid Level Controller (LLC) fails to operate properly
(gain instrument supply output) or the Level Control Valve (LCV or dump valve) fails to open or
operate properly.
If the LIQUID OVERFLOW condition occurs, the Level Safety High (LSH) has also failed to operate
properly.
Primary Protection: Primary protection from liquid overflow should be provided by an LSH
sensor to shut off inflow into the component.
Secondary Protection: Secondary protection from liquid overflow to the atmosphere should be
provided by the Emergency Support Systems. Secondary protection from liquid overflow to a
downstream component should be provided by safety devices on the downstream component.
(Example, LSH or PSH at Downstream Component)
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Primary Protection
Liquid Overflow
Downstream
Pressured Vessel LSH
Devices
Atmospheric Vessel LSH ESS
Cause: Liquid overflow can be caused by liquid input in excess of liquid outlet capacity. This may
be the result of failure of an upstream flow rate control device, failure of the liquid level control
system, or blockage of a liquid outlet.
Effect and Detectable Abnormal Conditions: The effects of liquid overflow can be
overpressure or excess liquids in a downstream component, or release of hydrocarbons to the
atmosphere. High level is the detectable abnormal condition that indicates that overflow may
occur.
Location of Safety Devices: The LSH sensor should be located a sufficient distance above the
highest operating liquid level of a component to prevent nuisance shutdowns, but with
adequate volume above the LSH sensor to prevent liquid overflow before shutdown is
accomplished.
GAS BLOWBY
GAS BLOWBY is the discharge of gas from a process component through a liquid outlet.
GAS BLOWBY occurs whenever a Liquid Level Controller (LLC) fails to operate properly (gain
instrument supply output) or the Level Control Valve (LCV or dump valve) fails to close or
operate properly.
If the GAS BLOWBY condition occurs, the Level Safety Low (LSL) has also failed to operate
properly.
Primary Protection: Primary protection from gas blow-by should be provided by an LSL sensor
to shut off inflow or shut off the liquid outlet.
Secondary Protection: Secondary protection from gas blow-by to a downstream component

should be provided by safety devices on the downstream component.
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Primary Protection
Gas Blowby
Downstream
Low Level LSL
Devices
Gas Blowby: Gas is being discharged into the water outlet.
NOTE: Gas Blowby may cause downstream component to Overpressure.
Cause: Gas blow-by can be caused by failure of a liquid level control system or the inadvertent
opening of a By-Pass Valve around a Level Control Valve (LCV).
Effect and Detectable Abnormal Conditions: The effect of gas blow-by can be overpressure in
a downstream component. Low level is the detectable abnormal condition that indicates gas
blow-by may occur.
Location of Safety Devices: The LSL sensor should be located a sufficient distance below the
lowest operating liquid level to avoid nuisance shutdowns, but with an adequate volume
between the LSL sensor and liquid outlet to prevent gas blow-by before shutdown is
accomplished.
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EXCESS TEMPERATURE
EXCESS TEMPERATURE (Fired and Exhaust Heated Components) is temperature above that in
which a process component is designed to operate. It is categorized as excess medium or
process temperature and excess Stack temperature.
Primary Protection: Primary protection from flame emission through the air intake of a natural
draft burner should be provided by a Flame Arrestor to contain the flame in the firing chamber.
Primary protection from flame emission through the air intake of a forced draft burner should
be provided by a PSL (air intake) sensor to detect low air-flow and shut off the fuel and air
supply.
A Stack Arrestor should provide primary protection from exhaust stack spark emission. Primary
protection form hot surfaces due to excess temperature should be provided by a TSH (medium
or process fluid) sensor and TSH (stack) sensor. The TSH sensor should shut off fuel supply an
inflow of combustible fluids.
Secondary Protection:
Secondary Protection: Secondary protection from flame emission through the air intake of a
natural draft burner should be provided by the Emergency Support System.
Secondary protection from flame emission through the air intake of a forced draft burner should
initiate a signal to shut-off the source of fuel and air supply.
Secondary protection from exhaust stack spark emission and hot surfaces should be provided by
the Emergency Support Systems and an FSV where applicable.
Detectable Abnormal
Primary Protection Secondary Protection
Conditions
Excess Temperature
Due to Excess Fuel TSH ESS
TSH (M or P Liquid &
Due to Low Level LSL
Stack)
Due to Low Flow FSL TSH (M Liquid)
At the Stack TSH ESS
Cause: Direct ignition sources can be caused by flame emission from the air intake due to the
use of improper fuel (e.g., liquid carry over in a gas burner), reverse draft from a natural draft
burner or extraneous fuel entering the air intake; spark emission form the exhaust stack or other
hot surfaces.
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Effect and Detectable Abnormal Conditions: the effect of a direct ignition source can be a fire
or explosion if contacted by a combustible material.
High temperature and low air flow (forced draft burners only) are the detectable abnormal
conditions that indicate a direct ignition source may occur.
Location of Safety Devices: The location of air intake Flame Arrestors and exhaust stack spark
arrestors is fixed. These items should be installed to facilitate inspecting and cleaning.
TSH (stack, media, process fluids) sensors should be installed as discussed elsewhere in this
manual.
PSL (air intake) sensor should be installed downstream of the blower fan inside the air intake on
a force draft burner.
Forced draft burners should have starter interlocks installed on the blower motor starter.
FSV should also be installed in medium tube outlet piping.
DIRECT IGNITION SOURCE
IGNITION SOURCE is the point of sufficient temperature and heat capacity to ignite a
combustible mixture (Example: Spark Flame or Heat).
Detectable Abnormal
Primary Protection Secondary Protection
Conditions
Direct Ignition Source
Natural Draft Burner Flame Arrestor ESS
Forced Draft Burner PSL BMI
Spark at the Stack Spark Arrest ESS
Hot Surfaces TSH ESS
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EXCESS COMBUSTIBLE VAPORS IN A FIRETUBE
EXCESS COMBUSTIBLE VAPORS in the Firing Chamber (Fired Component) are combustible
vapors in addition to those required for normal ignition of either the pilot or main burner.
.
Primary Protection: Primary protection from excess combustible vapors in the firing chamber
(caused by a mechanical failure of the fuel control equipment) should be provided by a flame
failure sensor.
The sensor should detect a flame sufficient to ignite the entering vapors and shut off the fuel.
The sensor may be the light detecting type (BSL), such as an ultraviolet, or the heat sensing type
(TSL).
Secondary Protection: Secondary protection from excess combustible vapors in the firing
chamber due to fuel control failure should be provided by a PSH (fuel sensor to shut off the
fuel). On the forced draft burner, a PSL (air) sensor and motor starter interlock should be
installed to detect an inadequate air supply and initiated a signal to shut off the fuel and air.
An FSL sensor may be installed in place of a PSL sensor in the air intake to sense low air flow.
In addition to the above safety devices, safe operating procedures should also be followed to
prevent firebox explosions during ignition of the pilot or main burner. Recommended safe
operating procedures are shown elsewhere in this manual.

Primary Protection
Excess Vapors in a Firetube

Natural Draft Burner BSL/TSL PSH (Fuel)
PSHL
Forced Draft Burner BSL/TSL (Fuel) PSL, FSL &
BMI
Cause: Accumulation of excess combustible vapors in the firing chamber can be caused by a
failure of the fuel or air supply control equipment or improper operating procedures.
Effect and Detectable Abnormal Conditions: The effect of excess combustible vapors in the
firing chamber, on ignition, could be an explosion and possible rupture of the component. Flame
failure and high or low fuel supply pressure are detectable abnormal conditions that could
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indicate excess combustible vapors in the firing chamber. Low air supply pressure and blower
failure may also indicate this condition in forced draft burners.
Location of Safety Devices:
A BSL or TSL sensor should be installed in the firing chamber to monitor the pilot and/or main
burner flame.
PSH and PSL sensors in the fuel supply should be installed downstream of all fuel pressure
regulators.
A PSL (air intake) sensor should be installed in the air intake downstream of the forced draft
blower.
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What function does a Safety Sensor perform?

A Safety Sensor is a device that detects an abnormal operating condition and transmits a signal
to perform a specific shutdown function.
- All shutdown devices, valves, and pressure sensors shall function in a manual reset
mode.
- Sensors with integral automatic reset like PSHL and LSHL shall be equipped with an
appropriate device to override the automatic reset mode. (Manual Reset Required)
(CRBBM)
- A PSV sensor is an integral automatic reset safety device that does not require a CRBBM
installed.
- All pressure and level sensors shall be equipped to permit testing with an external source.
Safety Sensor’s Output Signal:
Every Safety Sensor’s transmitted (output) signal must result in a minimum of two functions:
1) It must alarm and indicate. This is usually done by the First-Out Indicator’s response to
the detection of abnormality by the Safety Sensor.
2) A shutdown must occur to the source of inlet or incoming pressure and flow
Safety Sensor/Safety Device Control Function Review

BSL/TSL = Detects Flame Out in a fired vessel and shuts in the correct valve
PSL = Detects Low Pressure in a component and shuts in the incoming flow.
PSV = Relieves pressure in a component, eliminates Overpressure.
LSH = Detects a High Liquid Level in a vessel and shuts in or diverts the inlet flow.
LSL = Detects Low Liquid Level in a vessel and shuts in or diverts the inlet flow.
TSH = Detects High Temperature in a component and shuts in the correct shutdown valve.
TSE = A system of sensors (heat activated or temperature sensitive “fusible plugs” or electrical
thermocouples) located on or near process equipment used to detect a flame or fire to shut-in
the platform. It is also connected to the ESD system to provide the same results as an ESD.
TSE = ESD
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FSV = an inlet to outlet directional safety valve used to minimize or prevent backflow.
Each process outlet line shall have a FSV installed. An example is a three-phase separator
with an FSV on each outlet such as gas, oil and water lines.
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Subpart-O
Training
(PSST)
Module
3
Emergency Support Systems
(ESS) Components,
Other Support Systems,
&
Standard Process & Safety Component
Definitions
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Emergency Support Systems (ESS) Components

1. Emergency Shutdown System (ESD Station Locations)
a. Heliport Decks
b. Exit Stairway Landings (Each Deck Level)
c. Boat Landings (Synthetic Tubing “Polyflo” acceptable here only)
d. Center of the Bridge or at each end of the Bridge connecting two Platforms
e. Emergency Evacuation Stations
f. Near Driller’s console
g. Main Exits of living Quarters
h. Others as needed.
2. Fire Loop (Temperature Safety Elements – TSE)
a. Integrate with ESD Control Circuit (TSE = ESD)

b. According to TSE API RP 14C Table C-1 installation guidelines.
3. Other Detection Systems
a. Analyzer Safety High (ASH – Combustible Gas Detector)

(LEL Set points: 25% Alarm, 60% Shutdown)
b. Oxygen Safety High (OSH- Toxic Gas Detector)
c. Ultraviolet Safety High (USH – Flame Detector)
d. Ionization Safety High (YSH – Smoke Detector)
4. Spill Containment System
a. Divert spills to Sump System
5. Sub Surface Safety Valves (SSSV – Downhole Safety Valves)
a. Sub Surface Control Safety Valves (SSCSV)
Flow Characteristics actuated Valve Assembly (Commonly known as Velocity or

Storm Choke Valves. They are Differential Pressure operated. Normally the
internal pressure and flow across or through the valve assembly is maintained in an
equalized pressure status condition while the valve is in the normal operating
placement.
b. Surface Control Subsurface Safety Valves (SCSSV)
The SCSSV is Hydraulic Pressure Operated from a Surface Control Panel

(Hydraulic Wellhead system control circuit) on the platform.
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Other Support Systems

1. Pneumatic Instrument Supply (Pressure) System
a. Properly regulated or controlled Instrument Supply Pressure as required.

b. Filters to provide Instrument Supply Pressure that is free from all liquids and /or
solid particles.
c. A non-corrosive Instrument Supply Pressure source that is free from contaminants.
d. Time Delay components to provide closure of the SSV within 45 seconds of ESD
actuation and 2 minutes thereafter for closure of SCSSV
2. Relief (Exhaust), Vent & Flare Systems
a. Properly sized Pressure Safety Valves (PSV or Relief) and

Exhaust Piping/Manifold assemblies.
b. Properly sized Flared Scrubbers and associated exhaust piping.
c. Proper sizing of Blow Down Valve (BDV).
d. Proper sizing of Atmospheric Pressure relief (PSV or Vacuum) Safety Devices.
STANDARD PROCESS & SAFETY COMPONENT DEFINITIONS
Abnormal Operating Conditions: Conditions that occurs in a process component whenever an

operating variable ranges outside its normal operating limits.
Atmospheric Service: Refers to operation at Gauge Pressure between ½ oz. per square inch
vacuum and 5 PSI (pounds per square inch pressure).
Automatically Fired Vessel: Fired vessel with burner fuel controlled by an automatic
temperature control component or process controller.
Backflow: Fluid flow in a process component opposite to the normal flow. A Flow Safety Valve
(FSV) is installed to minimize or prevent the Backflow condition.
Blowdown Valve: (BDV) An automatically operated, Normally Open valve assembly used to
vent (discharge) pressure from a component or process station upon detection of a shutdown
condition.
Boarding Valve: (BSDV) A shutdown valve used as a secondary SSV on an incoming USV flow
line onto the floating facitility.
Containment System: Any method used on an offshore platform to collect and direct liquid
hydrocarbons to a safe location (generally the Sump system).
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Detectable Abnormal Condition: An abnormal operating condition that can be automatically

detected through required safety system sensors
Direct Ignition Source: Point of sufficient temperature and heat capacity to ignite a
combustible mixture.
Emergency Shutdown: (ESD) System of manual stations that when activated will initiate
platform shutdown by closing the SDV, SSVs, SCSSVs and opening of BDV.
Excess Temperature: Temperature in a heated or fired process component in excess of the

rated working temperature as detected by a Temperature Safety High (TSH) Media & Level
Safety Low (LSL) (Tube).
Failure: Improper performance of a device or equipment that prevent its competition of the
design function.
Fire Loop: (TSE) A pneumatic control system containing Temperature Safety Elements (TSE)
used throughout the platform to detect (sensor) a flame/abnormal heat on or around a
component.
Flame Failure: (BSL) Loss of a pilot light in a fired vessel. Flame Failure can be detected by a
Burner Safety Low (BSL) or Temperature Safety Low (TSL)
Flow Safety Valve (FSV) A safety device that will minimizes and or prevents back flow
FTP: Flowing Tubing Pressure is described as the measurement of pressure of a well stream
flowing or operating under normal conditions or circumstances.
Gas Blowby: The discharge of gas through a liquid outlet from a process component.
Gas Detection System: (ASH) Control system that monitors the gas and air combustible
mixture accumulation in a building and other locations of the platform.
High Liquid Level: Liquid level in a process component above the highest operating level.
High Pressure: Pressure in an operating component in excess of the maximum operating

pressure but less than the MAWP/MAOP.
Leak: Accidental escape of liquid and or gaseous hydrocarbons to the atmosphere.
Liquid Overflow: The discharge of liquid through the gas outlet, it is detected by the LSH.
Lower Explosive Limit: (LEL) The lowest concentration by volume of combustible gas in
mixture with air that can be ignited at ambient conditions.
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Low Liquid Level: Liquid level in a component below the lowest operating level as detected by
an LSL.
Malfunction: Any condition of a device or equipment that causes it to operate improperly, but
does not prevent the performance of its design function.
Maximum Allowable Operating Pressure (MAOP): The highest operating pressure allowable
at any point in a pipeline system during normal flow or static conditions.
Maximum Allowable Working Pressure (MAWP): The highest operating pressure allowable in
any component other than a pipeline during normal operating or static conditions.
Normally Closed Valve: A valve assembly that will shift to the closed position upon loss of the
operating power medium. The internal flow control components fail in the closed-to-flow
placement.
Normally Open Valve: A valve assembly that will shift to the open position upon loss of the
power medium. The internal flow control components fail in the open-to-flow placement.
Overpressure: Abnormal high Pressure in a process component in excess of its MAWP or MAOP.
Platform Shutdown: The Shutting in of all process stations of a platform production process
along with all support systems. An ESD condition has occurred or was initiated by alerted
personnel.
PSH: Safety Device (control) used to detect pressure increasing above the highest normal
operating pressure range. The Pressure Safety High (PSH) is the Primary protection against
overpressure.
PSL: Safety Device (control) used to detect pressure lower than the lowest operating pressure.
The Pressure Safety Low (PSL) is the Secondary protection against underpressure.
PSV: A relief safety device for used to prevent overpressure. The Pressure Safety Valve (PSV) is
a secondary protection device on a vessel or process component.
Process Component: A single, functional piece of production equipment and associated piping
used in a process station or system.
Process Shutdown: The isolation of a specific process station or component from the process
system by closing the proper SDVs to shut-in the source of both pressure or flow to the process
station or divert flow to another process station.
Sensor: A device that detects an abnormal operating condition and transmits a signal to
perform a specific shutdown function.
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Shutdown Valve: (SDV) An automatically operated, Normally Closed valve used for isolating a
process station or component. It shuts off the source of pressure and flow.
Shut in Tubing Pressure: (SITP) is described as pressure that is indicated on the wellhead
Pressure Gauge (PG) whenever there is no flow or a static pressurized condition exits. It
represents the maximum pressure potential on a specific oil/gas well at the time of the pressure
test.
Surface Controlled Sub Surface Safety Valve: (SCSSV) Control valve in the well below the
mudline (100’) that is controlled by hydraulic pressure from a panel on the platform.
Surface Safety Valve: (SSV) An automatic wellhead valve assembly that will close (Normally
Close) upon loss of operating power.
Temperature Safety Elements: (TSE) Safety components used throughout the platform that
will detect or sensor flame on or around a component. (TSE = ESD)
Underpressure: Pressure in a process component less than the collapse pressure that poses a
risk to safety.
Undesirable Event: An adverse occurrence in a process component that poses a risk to safety.
Vent: A pipe or fitting on an atmospheric vessel that is open to atmosphere to prevent

overpressure.
EMERGENCY SUPPORT SYSTEMS

Emergency Support Systems (ESS) and other support systems provide a method of performing
specific safety functions common to the entire platform.
The ESS includes the ESD, fire detection, gas detection, ventilation, containment
systems and sumps and SSSV system. These are essential systems that provide a level of
protection to the facility by initiating shut-in functions or reacting to minimize the
consequences of the released hydrocarbons.
The other support systems include the pneumatic supply systems, systems for discharging gas to
the atmosphere, systems for containing leaks or spills, and any other service system that might
enhance platform safety. The pneumatic supply system provides a control medium for the
safety system and the systems for discharging gas to the atmosphere provide a means of
discharging gases to the atmosphere under safe, controlled conditions.
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Emergency Shutdown (ESD) System

Purpose: An Emergency Shutdown (ESD) system is a multitude of manual control stations
strategically located on a platform that, when activated, will initiate shutdown of all wells
(SSV’s and SCSSV’s) and other process stations. This system may include a number of
independent process shutdown systems that can also be actuated separately. Activation of the
ESD system should result in the termination of all production activity on the platform, including
the closing of all pipeline SDVs. The ESD system should be designed to permit continued
operation of electric generating stations and fire fighting systems when needed in an
emergency.
The ESD system provides a means for personnel to manually initiate platform shutdown
when an abnormal condition is observed. Fusible elements (TSE) of the fire loop may be
integrated with the ESD control loop.
Shutdown Stations
Stations for activation of the ESD system for complete platform shutdown should be located as
follows: as Per API RP 14C Table C.1.1.2
a. Helicopter decks.
b. Exit stairway landings at each deck level.
c. Boat landings.
d. At the center or each end of a bridge connecting two platforms.
e. Emergency evacuation stations.
f. Near the drill’s console during drilling and work-over operation.
g. Near the main exits of living quarters.
h. Other locations as needed to provide stations accessible to all Platform areas.
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ESD stations should be conveniently located but should be protected against accidental
activation. ESD stations should be identified by shutdown function, and the shutdown position
of the valve handle should be clearly indicated. The manually operated ESD valve shall be
quick-opening and non-restricted to enable rapid actuation of the shutdown system.
Because of the key role or the ESD system in the platform safety system, a high quality corrosion
resistant valve should be used. ESD stations at boat landings may utilize a loop of synthetic
tubing in lieu of a valve but requires the use of plastic ferrules for easy release.
Fire Detection System

Purpose:
A method of automatically detecting fires on an offshore platform should be provided to allow

for early response. Pneumatic fusible element (TSE) systems or various electrical fire
detection devices, including flame (USH), thermal (TSH), or smoke (YSH) detection devices,
should be installed in all areas classified (Division 1 and 2) by API Recommended Practice
500 and in all buildings where personnel regularly or occasionally sleep.
Fusible Element Systems (TSE):
One reliable and widely used method of detecting fires is a pneumatic system containing
strategically located fusible plug elements (TSE). This system should be capable of providing a
signal to shut down production activities except for equipment required to control the fire.
Fusible elements normally are lead filled plugs that melt at a designed temperature (Normally
160 Degrees) or a section of fusible synthetic tubing. Note Word of Caution: Do not use fusible
tubing if using a fuel gas instrumentation system is used.
Process equipment:
API RP 14C Table C-1 presents guidelines for the installation of fusible plugs. When fusible
tubing or other devices (e.g., ultraviolet flame detectors, infrared sensors, etc.) are used in lieu
of fusible plugs, they should provide at least the same coverage as outlined in Table C-1. Fusible
elements may be installed in the various pneumatic lines of the safety system if the signal
generated initiates the proper shut-in functions. Fusible elements should not be installed in a
combustible gas supply line that would continue to exhaust after shutdown.
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API RP 14C
Table C-1 - Guidelines for Fusible Plug Installations
Min. No.
Component Fusible Plug Arrangement
of Plugs
b
Wellheads One for each wellhead -
Headers One for each 10 feet (3m) of header length 2

Pressure Vessels:
Vertical Vessel One for each 12 inches (0.3m) of OD to a max of 5 1
Less than 48 inches (1.2m) OD – one for each 5 feet (1.5m) of
Horizontal Vessel 2
length –
Greater than 48 inches OD, two for each 5 feet of length in two
Horizontal Vessel 4
parallel rows.
Atmospheric Vessels One for each vessel process inlet, outlet and hatch -
Same as pressure vessels. Additionally, one out-side the flame

Fired Vessels & Exhaust Heated Components -
arrestor on fired components.
Heat Exchangers (Shell-Tube) One for each end of heat exchanger 2

Pumps:
Reciprocating One over rod packing -
Centrifugal One over each packing box -
Compressors:
Reciprocating One for each cylinder -
Centrifugal One over compressor case -
Engines
Spark Ignition One over each carburetor or fuel injection valve. -

Diesel One for pump supplying injectors -
Combustion Turbines One for each fuel solenoid, governor valve and PTO pump -
a Or equivalent coverage
b Not applicable to underwater wellheads or headers
Note: When fusible tubing or other devices (such as Ultraviolet Flame Detectors USH within an enclosure, etc.) are
used instead of Fusible Plugs (TSE), they should provide at least the same coverage as outlined above.
Note: TSE installed over every hydrocarbon handling electric motor.
Note: There is an additional requirement to place a TSE within (5) five feet of the incoming BSDV
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Enclosed Classified Areas

Enclosed areas that are classified (Division1 or Division 2) by API Recommended Practice 500
should be equipped with fire (flame, thermal, or smoke) detection devices that automatically
shut in the hydrocarbon sources causing the enclosed areas to be classified. A fusible plug
system using either combustible or non-combustible gas is acceptable in these areas.
Electrical Fire Detection Systems

In addition to pneumatic fusible element (TSE) systems, various electrical fire detection devices
(flame, thermal and smoke) are commonly used on offshore production platforms. These
devices are utilized to activate alarms, initiate shut-in actions, or activate fire suppression
systems (e.g.: CO2, or water).
Installation and Operation

All electrical fire detection devices should be approved by a nationally recognized testing
laboratory and installed in accordance with manufacturer’s recommendations. Electrical fire
detection devices should be capable of operating a minimum of 8 hours without primary
platform electrical power.
The installation and operation of a fire detection system should be suitable for the area it is
designed to protect. Fire detection systems should be installed for process equipment, enclosed
classified areas, and enclosed unclassified areas as follows:
Enclosed unclassified areas.

All rooms in which personnel regularly or occasionally sleep should be equipped with smoke
detectors that activate an audible alarm. Rooms containing heat sources (e.g., water heaters,
clothes dryers, kitchen ranges, ovens, space heaters, etc.) should be equipped with smoke and/or
thermal rate of rise detectors that activate an audible alarm. Fusible plug systems utilizing a
combustible gas should not be used for fire detection in buildings where personnel regularly or
occasionally sleep (even if the building is classified because of its proximity to a hydrocarbon
source).
Combustible Gas Detection System

Purpose:
The accumulation of combustible gases in the atmosphere on offshore platforms could create a
threat to safety. Accumulations are more likely to occur in enclosed areas. Two methods for
increasing safety are providing adequate ventilation and installing combustible gas detector
systems.
The gas detector (ASH) system should alert personnel by audible and / or visual alarm to the
presence of low level concentrations of flammable gas vapor. Also, it should either shut off the
gas source or remove all sources of ignition if the concentration approaches the lower explosive
limit (LEL) of the gas present.
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Analyzer Safety High (ASH – Combustible Gas Detector) (LEL Set points: 25% Indicates & Alarm,
60% Total Shutdown)
Oxygen Safety High (OSH- Toxic Gas Detector)
H2S Detectors beyond 20 PPM or greater where it is produced, processed, or otherwise handled
H2S Portable Detectors with 10 PPM Concentration Detection
SO2 Detectors where H2S is monitored
Installation
Combustible gas detecting sensors should be located (a) in all enclosed areas that are classified
(Division 1 or Division 2) by API Recommended Practice 500, (b) in all enclosed areas that contain
natural gas-fueled prime movers, and (c) in buildings where personnel regularly or occasionally
sleep and that contain a flammable gas source. Gas detection instruments should be approved
by a nationally recognized testing laboratory (NRTL) and should meet requirements put forth by
ANSI/ISA S12.13, Part I: Performance Requirements, Combustible Gas Detectors. Shutdown
devices controlled by gas detector systems should be “normally energized” (commonly referred
to as “fail-safe”).
Gas detection systems should be installed operated, and maintained in accordance with ANSI/ISA
S12.13, Part II: Installation, Operation, and Maintenance of Combustible Gas detection
Instruments.
In enclosed areas containing flammable gas compressors, the minimum number of sensors in
one per compressor unit, plus an additional sensor per three units or fractional part thereof.
NOTE: This requires a minimum of two sensors in all enclosed compressor buildings. In enclosed
areas containing other natural gas-fuel prime movers (e.g., engines driving generators or
pumps), the minimum number of sensors is one per prime mover.
Providing adequate ventilation is an acceptable alternative to installing gas detection systems

except in buildings where personnel regularly or occasionally sleep, or in enclosed areas that
contain compressors handling flammable gas. Likewise, gas detection may be omitted in
enclosed areas on platforms not provided with continuous AC power if the enclosed area
contains no ignition source, contains no compressor handling flammable gas, and is not a
building where personnel regularly or occasionally sleep.
Operation and Maintenance
Gas detection instruments should provide continuous monitoring and be able to detect at least
two gas concentration levels. An audible alarm signal (visual signal in high noise areas where an
audible alarm in ineffective) should be activated at no greater than 25 percent LEL to alert
operating personnel. Automatic corrective action, e.g., closing SDVs on gas sources or
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disconnecting electrical power to equipment not suitable for locations classified as hazardous,
should be initiated at no greater than 60 percent LEL.
In lieu of total process shut in, it is acceptable to isolate alarmed areas; an example is closing a
fuel valve to a generator building. Careful consideration should be given to the form of
automatic corrective action taken to ensure that the situation is not made more hazardous. If
machinery or equipment shutdown could create an ignition source, consideration should be

given to actuation of a fire inerting system, e.g., Halon, prior to shutdown. Gas detection
systems monitoring more that one area should identify location where flammable gas or vapor
detected.
Adequate Ventilation
Adequate ventilation is ventilation (natural or artificial) that is sufficient to prevent the

accumulation of significant quantities of vapor-air mixtures in concentrations above 25 percent
of their lower explosive limit (LEL). Refer to API Recommended methods of achievement.
Containment System
A containment system is installed to collect and direct escaped liquid hydrocarbons to a safe
location. All equipment subject to leaks or overflow should be protected by curbs, gutters or
drip pans that drain to a sump system. Containment systems are optional on structures that do
not have process vessels or other equipment subject to leak or overflow (e.g., structures with
only well, headers, pipelines, cranes, and / or instrument gas scrubbers).
All gravity drain piping networks should be designed to prevent escape of gas from sumps
through the drains. This is typically accomplished by water seals located at each drain, or each
drain-pipe header, or with a total network water seal located in the sump inlet piping. Check
valves are not considered appropriate for this service and should not be used as alternative
protection for water seals. Pressure drains should not the combined with gravity drains prior to
sump entry.
Sumps (General)
A Sump may be a tank, a closed end-pipe, or an open-end pile. All sumps should be equipped
with an automatic discharge to handle maximum inflow. Vents are installed on atmospheric
sumps for the purpose of safely dissipating hydrocarbon vapors. Depending upon design and
location, a sump pile vent may fulfill this purpose without a flame arrestor being installed. Due
to possible plugging from corrosion, the low flow/low pressure (no static electricity), and
distance from potential ignition/flash back sources, a flame arrestor could be eliminated in a
sump pile located close to the water level.
Open-End Sump Piles
Properly designed open-end sump piles are occasionally used to collect deck drainage or drips
and to dispose of treated produced water. Except during emergency upset condition, vessels
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(e.g., flare scrubbers, condensate accumulators, and various fuel filter scrubbers) should not
discharge liquid hydrocarbons directly into an open-end sump pile. Open-end sump piles should
be protected against hydrocarbon discharge (overflow and/or underflow). The type of
protection should be determined on a case-by-case basis. Some factors that should be
considered include pile length, liquid properties, maximum in-flow rate, wave action, and tidal
fluctuation.
Subsurface Safety Valves (SSSV)
SSSVs are installed below the wellhead to prevent in controlled well flow in the event of an
emergency situation.
Subsurface controlled SSSV (SSCSV) (Storm Choke) should shut in if well rate exceeds a
predetermined rate that might indicate a large leak.
Surface controlled SSSVs (SCSSV) should shut in when activated by an ESD system and/or a fire
loop. Guidance for the design and installation of SSSVs is covered in API Recommended Practice
14B.
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Other Support Systems (Pneumatic Supply System)

Purpose: The pneumatic supply system provides the control medium for the surface safety
system. The platform safety and shutdown systems generally require a power supply at a
pressure adequate to operate valve actuators and an instrument supply at a lower pressure.
Pneumatic Supply Properties
Proper functioning of the safety system is dependent on the pneumatic supply; therefore, a
reliable source of high quality gas is essential. The following are properties of a good pneumatic
supply:
a. Free of liquid hydrocarbons
b. Free of water and water vapor
c. Free of solids
d. Non-corrosive
Pneumatic Supply Sources
Usually, air, natural gas, or nitrogen is the pneumatic control medium. When air is used as a
pneumatic supply source, the system should be designed to prevent the mixing of air and
hydrocarbon gases from the process or utility systems under both normal and abnormal
conditions. If an alternate pneumatic supply source is provided, the alternate medium must be
of a composition that will not create a combustible mixture when combined with the primary
source.
Supply and Response
The pneumatic supply distribution systems should be sized to assure adequate volume and
pressure to all safety devices. Pneumatic supply usage should be calculated for the maximum
condition that could be experienced at any one time. The time it takes for any safety device (e.g.
PSH, BSL, ESD station, etc.) to effect component or platform shutdown should not exceed 45
seconds. To achieve this response, consideration should be given to pneumatic line sizes, safety
device exhaust port size and the use of auxiliary quick-exhaust devices. Pneumatic lines that
supply and bleed should be sized for optimum discharge conditions. Because of volume and
flow characteristics a line that is either too large or too small will require excessive time to
exhaust. API Recommended Practice 550 should be used as a guide when designing instrument
and control systems.
Systems for Discharging Gas to Atmosphere (Vent & Flare)

Purpose: Systems for discharging gas to the atmosphere provide a means for conducting
discharged gas from process components under normal conditions (flare, vent) and abnormal
conditions (relief) to safe locations for final release to the atmosphere. These should be
locations where the gas will be diluted with air to below the LEL so it will not be a threat to the
facility or where it can safely be burned.
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Description: These systems originate at the normal gas exit or pressure relief device of a
process component and terminate at the designated safe locations. They can vary from an exit
pipe nipple on an individual PSV or control valve to a piping network connected to the outlet of
several valves. If gas is discharged from a pressure vessel during normal operation (flare, vent) a
scrubbing vessel should be provided to remove liquid hydrocarbons.
Note:
Vent is where there is gas only is being release into the atmosphere. This is normally what
happens on and OCS Platform
Flare is where gas is being released to the atmosphere but the difference is where at the end of
the vent boom is a fire has been ignited to burn off any excess gas. H2S facilities have this
continuously fire burning
Discharge Point: The final discharge point for atmospheric gas may be through a vertical,
cantilevered, or underwater pipe. In some cases the discharge point may be remote from the
platform. The following should be considered in selecting a safe discharge point:
a. Personnel safety
b. The discharge volume
c. The location in relation to other equipment, particularly fired vessels r other ignition
sources, personnel quarters, fresh air intake systems, and helicopter and boat
approaches
d. Prevailing wind direction and, in the case of underwater discharges, the prevailing
current.
Design Considerations: Atmospheric gas discharge systems should be designed in accordance

with API Recommended Practice 520 and API Recommended Practice 521, API Specification
2000, and Section VIII of the ASME boiler and Pressure Vessel code. Systems should be designed
so that back-pressure, including inertial forces developed at maximum instantaneous flow
conditions, will not exceed the working pressure of the lowest pressure rated item. Flame
Arrestors can be used in vent systems to reduce the danger of combustion within the
component from an external source. A Flare Scrubber should be a pressure vessel designed to
handle the maximum anticipated throughput flow rate.
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Subpart-O
Training
Module
4
Code of Federal Regulations
API RP 14C
Safety System Information
&
30 CFR 250 Production & Drilling Safety
Regulations
30 CFR 254 Oil Spill Response Regulations

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API RP 14C
SAFETY SYTEMS INFORMATION
What subjects are referenced in API RP 14C?
It is the American Petroleum Institute - Recommended Practice 14C (API RP 14C) guidelines
for the analysis, design, installation, and testing of basic surface safety systems
for offshore production platforms.
What other information is provided in API RP 14C?

API RP 14C also references the safety devices used, their identification, and system analysis
of components, protection concepts and the location of safety devices on the components.
What’s it the primary purpose of the platform safety system

information found in API RP 14C?
The purpose of the platform safety system is to protect

personnel, the environment, and the facility from threats to
safety (any adverse occurrences).
How does it accomplish the basic protection task listed above?
The task is accomplished by eliminating any inherent weakness in the process components by
providing two levels of protection (Primary and Secondary) that are
functionally different and independent of the normal control
system.
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Department Of Interior (DOI)
Bureau of Safety and Environmental Enforcement (BSEE)
Bureau of Ocean Energy Management (BOEM)
30 CFR 250 and 30 CFR 254
Code of Federal Regulations

What is the Code of Federal Regulations 30 CFR 250 & 30 CFR 254?
A collection of federal laws (regulations) compiled by a branch of the Department of Interior
(DOI) (Congress approval, or Presidential Signature)
BSEE (Bureau of Safety and Environmental Enforcement known as the BSEE) is the regulatory
enforcement entity regarding all (OCS) outer continental shelf operations Atlantic, Gulf of
Mexico, California, Alaska waters from the state OCS boundary to the 200 mile offshore
international boundary limit line.
BOEM (Bureau of Ocean Energy Management) is the regulatory agency that handles the OCS
leasing, sales and negotiations, environmental issues, royalty measurement, renewable energy
programs
What information is found within these Codes of Federal

Regulations? (30 CFR 250 & 254)
Within 30 CFR 250 & 254 are listed the regulations that set the minimum requirements for the
drilling and processing of oil and gas in the outer continental shelf (OCS).
What is the difference between the 30 CFR 250 & 254 and API RP 14C, if they
both reference or govern safety systems?
The difference is defined by the letter R. Within API RP 14C the letter R is determined to
mean the word RECOMMENDED. In 30 CFR the letter R means the word REGULATIONS.
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API RP 14C provides suggested RECOMMENDATIONS (Practices) for safe operation of

offshore platforms or process facilities.
Within 30 CFR 250 & 30 CF 254, its REGULATIONS (as found within) are Federal Laws that
shall to be implemented and obeyed.
Subpart A (General Information

Oral Approvals
The appropriate BSEE official (District Manager) may give an oral approval whenever the
regulations in this part require a lessee or other applicant to obtain such official’s approval
before commencing an operation or activity.
If an approval is given in response to an oral request, the lessee or applicant shall confirm the
oral request by submitting a written request on company letterhead within 72 hours of the oral
approval and the BSEE official shall approve that request subject to any conditions that were
placed upon the oral approval. In the event a written application is given oral approval by a BSEE
official, the BSEE official shall forward the approval and any conditions placed thereon to the
applicant.
Note: Email correspondence may be used for quick approvals between lessee and BSEE but a
written letter must follow. Print out all email references and place on file at field office
The appropriate BSEE official may give orders to lessees to connection with requirements of this
part whenever circumstances do not permit the time needed to prepare and issue such orders in
writing. (Email) Oral orders shall be confirmed in writing. Oral orders shall be confirmed in
writing by the appropriate BSEE official.
Facility Identification
Platforms, structures, artificial islands, and mobile drilling units which have helicopter landing
facilities shall be identified with at least one sign using letters and figures not less than 12 inches
in height. Signs shall be affixed at a location that is visible to approaching traffic and shall
contain the following information which may be abbreviated:
(1) Name of the lease operator (Abbreviation Okay)

(2) The area designation based on OCS Official Protraction Diagrams (except in the
Pacific OCS Region) Example Ship Shoal (SS)
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(3) The block number (lease number in the Pacific OCS Region) in which the facility is
located. SS 26
(4) Platform, structures, or rig name. L
(5) Example OIL ST 26-L
For each single completed well, the lease number (OCS-G-XXXX) and well number (B-29) shall be
painted on the wellhead or on a sign affixed to the wellhead Flowline or well head or if single
well platform identification sign. In wells with multiple completions, each completion shall be
individually identified at the wellhead.
For sub-sea wellheads, the required sign shall be affixed to the flow line at a convenient surface
location on the platform to which it is connected Incoming BSDV - Boarding Shut Down Valve
Area All identifying signs shall be maintained in a legible condition at all times
Facility Heliport Identification
• Heliports Identification requirements Pinc G-100 Part 250.154

• Heliport load rating with at least 12” high letters (FAA)
• 12 Over 38, See Above Heliport (12 Thousand Lbs Capacity X 38 Feet Square)
• Lessee or Operator Name (Can Be Abbreviated) 12” Letters
• Platform Area Block Designation
• Example (SS62-B)
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Safe and Workmanlike Operations

The lessee shall perform all operations in a safe and workmanlike manner and shall maintain all
equipment in a safe condition of the lease and associated facilities, the health and safety of all
persons and the preservation and conservation of property and the environment.
The lessee shall immediately take all necessary precautions to control, remove, or
otherwise correct any hazardous oil and gas accumulation or other health, safety, or fire
hazard.
Access to Facilities
The lessee shall make available for inspection by BSEE representatives, all platforms, artificial
islands, and other installations located on offshore leases. For installations equipped with
helicopter landing sites and refueling facilities, and the lessee shall provide the use of those
facilities for helicopters used by the BSEE in the supervision of offshore operations.
Lessee and non-lessee owners of easements, rights-of-way or other permits shall make available
at all reasonable times for inspection by BSEE the area covered by the lease, easement, right-of-
way, or permit, all improvements, structures, and fixtures thereon, and all records relative to the
design, construction, operation, maintenance, repairs, or investigations on or with regard to such
area.
The lessee shall, on request, furnish food, quarters, and transportation for BSEE
representatives to inspect lease facilities and operations. Upon request no later that 90 days
after furnishing food, quarters, and transportation, the lessee will be reimbursed for the costs
incurred for the food, quarters, and transportation provided BSEE representatives as
determined by the Regional Director.
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BSEE Inspection Fees

• BSEE Non-Refundable Inspection Fees (As Per 2013)
• $10,500/Year for facilities with no wells but with processing equipment or gathering lines
• $17,000/Year for facilities with 1-10 wells with any combination of active or inactive wells
• $31,500/Year for facilities with more than 10 wells with any combination of active or
inactive wells
• $30,500/Year per inspection for drilling rigs operating in more than 500 ft of water
• $16,700/Year per inspection for drilling rigs operating in less than 500 ft of water
Best Available and Safest Technologies (BAST)

The Director shall require on all new drilling and production operations and wherever
practicable, on existing operations, the use of the BAST, which the Director determines to be
economically feasible, where ever failure of equipment would have a significant effect on safety,
health, or the environment, except where the Director determines that the incremental benefits
are clearly insufficient to justify the incremental costs of utilizing such technologies.
Conformance to the standards, codes and practices referenced in this part will consider being
the application of BAST. Specific equipment and procedures or systems not covered by
standards, codes, or practices will be analyzed to determine if the failure of such would have a
significant effect on safety, health, or the environment. If such are identified and until specific
performance standards are developed by BSEE and as directed by the Regional Supervisor on a
case-by-case basis, the lessee shall submit such information necessary to indicate the use of
BAST, the alternatives considered to the specific equipment or procedures, and the rationale as
to why one alternative technology was considered in place of another. This analysis shall include
a discussion of the costs involved in the use of such technology and the incremental benefits to
be gained.
Crane operations
Crane installed on fixed platforms shall be operated and maintained in accordance with the
provisions of the American Petroleum Institute (API) recommended Practice (RP) for Operation
and Maintenance of Offshore Cranes (API RP 2D) to ensure the safety of facility operations.
Records of inspection, testing, Maintenance, and crane operator qualifications in accordance

with the provisions of API RP 2D shall be kept by the lessee at the lessee’s field office nearest
the Outer Continental Shelf (OCS) facility for a period of four (4) years. Deepwater facilities
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Five ( 5) years, All design, repairs, and construction records including the required anti-two
block safety devices installation shall be retained for the life of the crane at the OCS field office
Hot Work 30 CFR 250.109 – 30 CFR 250.113
There following should be in the Lessee Approved Welding and Hot Work permitting plan in field
documents, Drawings Showing Designated Safe Work Areas
All welding, burning, and hot-tapping activities shall be conducted according to the specific
requirements in 30 CFR 250.109 - 250.113 of this part, Practices and Procedures for Safe Hot
Work
Verify portable gas detector has been calibrated and documented
All welding, burning, and hot-tapping activities shall be conducted according to the specific
requirements in CFR 250.109 – 250.113 of this part.
1. Copy of Approval Plan

2. Drawings Showing Designated Safe Work Areas
3. Practices and Procedures for Safe Hot Work
4. Grounding of all Generators and Welding Machines
Permitting
Verify all LEL’s is recorded in a timely manner on the hot work permit.
Verify that all personal equipment devices and electrical tools (e.g., pagers, cell phones, drills,
cameras, video equipment) used in classified areas are suitable for the location or are used in
conjunction with an authorized “Hot Work Permit.” Pinc F-105
The PIC Person in Charge, Project Supervisor, Hot Work Crew Supervisor, and the Fire Watch
shall verify and sign off on the hot work permit that it is safe for hot work to commence in all
designated areas, piping, overboard water discharges
Fire Watch Duties
• Verify LEL’s as lessee policy requires is recorded on a signed and approved hot work
permit
• Fire watch to verify that hot areas is free of combustibles and safe to weld before any
hot work commences
• Fire watch is to have no other duties,
• He or she is to have the required fire-fighting equipment next to person for quick access
and use, Do Not Use the facility dedicated facility station fire equipment
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• Wait 30 minutes after hot work to verify smoldering or small fires has not re-occurred.
• Fire watch should carry a copy of the Hot Work Permit on his person at all times
• Move any flammable substances at least 35 feet away from point of impact by slag,
sparks, etc. or protect with fire resistant guards or curtains before any hot work begins.
• Any hot work performed in the well bay or production area within a 10 Foot area requires
the wells or production component be shut in
Grounding
• All equipment like welding machines, rotating equipment, separators, pumps, electric
motors extension cords, separators (if not welded down) etc. All must have a ground
cable attached from equipment to platform. Each individual grounding conductor should
be bare, or if insulated, have a continuous outer finish that is either green or green with
one or more yellow stripes
• The attachment point from the equipment to a platform connection should be bolted on
with the paint scrapped off where the wire grommet is attached to the wire. A ground clip
designed only for electrical grounding can be used.
• Regular beam clamps are approved by Underwriters Laboratories (UL) and Factory Mutual
Research Corporation (FM) to mount and support conduit and cable from structural
beams, not as temporary or permanent external equipment grounding conductors
• It is determined that the use of beam clamps as grounding conductors could potentially
cause fires and present electrical hazards to personnel.
• Verify welding and ground leads has no cuts or smashes. This leads can be repaired with
approved repair kits. Protect these leads when they are placed upon a grating surface
• All equipment that is placed in a staging area for removal or just arrived does not have to
be grounded. Example: A wireline unit, welding machine, generator , Reminder: that any
equipment in place for work project has to be grounded.
• Grounding lead is required between lift boat and platform due to static electricity
possibilities
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Electrical Codes
All areas shall be classified in accordance with Classification of Areas and Zones for Electrical
Installations at Offshore Drilling Rigs and Production Fixed and Floating Facilities for Offshore
Production except when not applicable.
• API RP 500 Is the Classification of all platform areas for Electrical Installations at OCS
Facilities
• API RP 505 Is the Classifications of Locations for Electrical Installations at OCS Facilities
Classified as Class 1, Zones 0, Zone1, Zone 2
All electrical installations shall be made in accordance with Design and Installation of Electrical
Systems for Offshore Production Platforms except when not applicable
• API RP 14-F is the Designed, Installation, and Maintenance of electrical systems
• API RP 14FZ is the Design, Installation and Maintenance of Classified Zones
• API RP 14G is the Fire Prevention and Control on Production Platforms
• API RP 14J is the Design and Hazard Electrical Analysis
Electrical Sources
Verify that portable electric tools: Pinc F-106

Used in Class I, Group D locations are permanently labeled certifying their use is approved for
these locations.
The ones that have warning labels certifying their use in hazardous locations are permanently
labeled
“WARNING – SOURCE OF IGNITION WHEN IN USE”.
The UL label has to be also attached to electrical tool device
All engines with electrical ignition systems shall be equipped with a low-tension ignition system
designed and maintained to minimize the release of sufficient electrical energy to cause ignition
of an external, combustible mixture or substance.
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Electrical Maintenance
Maintenance of electrical systems shall be by personnel who are trained and experienced with
the area classifications, distribution system, performance characteristics and operation of the
equipment, and with the hazards involved
Subpart C - Pollution Prevention and Control
Pollution Prevention
During the exploration, development, production, transportation of oil and gas or sulphur, and
lessee shall take measures to prevent unauthorized discharge of pollutants into the offshore
waters.
The lessee shall not create conditions that will pose unreasonable risk to public health, life,
property, aquatic life, wildlife, recreation, navigation, commercial fishing, or other uses of
the ocean.
Oil Spill Contingency Plans 30 CFR 254.5
An Oil Spill Contingency Plan (OSCP) shall be reviewed and updated annually, and all
modifications of the (OSCP) shall be submitted to the BSEE Regional Supervisor for approval. A
copy of the approved Oil Spill Response plan and approval letter shall be kept on file and for
easy access in the nearest field office
Oil Spill Training and Drills 30 CFR 254.48
Lessees conducting oil, gas and gas or sulfur operations in the Outer Continental Shelf (OCS)
shall ensure that the Oil Spill Response Team is provided with hands-on training classed at least
annually (yearly) in the deployment and operation of the pollution control equipment to which
they are assigned.
• Drills for familiarization with the pollution control equipment and operational procedures
shall be held when the equipment is placed initially and at least once every twelve (12)
months by the lessee or a contractor servicing the lessee.
• The personnel identified as the Oil Spill Response Operating Team in the Oil Spill
Contingency Plan (OSCP) shall participate in these drills.
• Drill conditions, results and the names of the participants in the drill shall be recorded,
and the records shall be maintained for two (2) years at a site designated in the Oil Spill
Contingency Plan (OSCP) and made available to BSEE personnel.
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• At least once annual a prep exercise will be conducted between the facility operator (Lead
operator) and Oil Spill Response Plan chain of command and documented and a copy
placed in facility file folders
When pollution occurs as a result of operations conducted by or on behalf of the lessee and the
pollution damages or threatens to damage life (including fish and other aquatic life), property,
any mineral deposits (in areas leased or not leased), or the marine, coastal, or human
environment, the control and removal of the pollution to the satisfaction of the BSEE District
Supervisor shall be at the expense of the lessee.
Immediate corrective action shall be taken in all cases where pollution has occurred.
Corrective action shall be subject to modification when directed by the BSEE District Supervisor.
If the lessee fails to control and remove the pollution, the Director, in cooperation with other
appropriate Agencies of Federal, State, and local governments, or in cooperation with the
lessee, or both, shall have the right to control and remove the pollution at the lessee’s expense.
Such action shall not relieve the lessee of any responsibility provided for by law.
The BSEE District Supervisor may restrict the rate of drilling fluid discharges or prescribe
alternative discharge methods. The District Supervisor may also restrict the use of components,
which could cause unreasonable degradation to the marine environment. No petroleum-based
substances, including diesel fuel, may be added to the drilling mud system without prior
approval of the District Supervisor.
Approval of the method of disposal of drill cuttings, sand, and other well solids shall be obtained
from the BSEE District Supervisor.
All items that is loose must be marked with a durable marker (Example: Paint Stick or Paint
Stencil) that identifies the owner or platform ID and resist the environmental effects
All hydrocarbon-handling equipment for testing and production such as separators, tanks, and
treaters shall be designed, installed, and operated to prevent pollution. Maintenance or repairs,
which are necessary to prevent pollution of offshore waters, shall be undertaken immediately.
Curbs, gutters, drip pans and drains shall be installed in deck areas in a manner necessary to
collect all contaminants not authorized for discharge. Oil drainage shall be piped to a properly
designed, operated, and maintained sump system which will automatically maintain the oil at a
level sufficient to prevent discharge of oil into offshore waters.
All gravity drains shall be equipped with a water trap or other means to prevent gas in the sump
system from escaping through the drains. Sump piles shall not be used as processing devices to
treat or skim liquids but may be used to collect treated-produced sand or liquids from drip pans
and deck drains and as a final trap for hydrocarbon liquids in the event of equipment upsets.
Improperly designed, operated, or maintained sump piles, which do not prevent the discharge of
oil into offshore waters, shall be replaced or repaired.
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On artificial islands, all vessels containing hydrocarbons shall be placed inside an impervious
berm or otherwise protected to contain spills. Drainage shall be directed away from the drilling
rig to a sump. Drains and sumps shall be constructed to prevent seepage.
Disposal of equipment, cables, chains, containers, or other materials into offshore waters is
prohibited. Materials, equipment, tools, containers, and other items used in the Outer
Continental Shelf (OCS) which are of such shape or configuration that they are likely to snag or
damage fishing devices shall be handled and marked as follows: All loose material, small tools,
and other small objects shall be kept in a suitable storage area or a marked container when not
in use and in a marked container before transport over offshore waters.
All cable, chain, or wire segments shall be recovered after use and securely stored until suitable
disposal is accomplished.
Skid-mounted equipment, portable containers, spools or reels, and drums shall be marked with
the owner’s name prior to use or transport over offshore waters and all markings must clearly
identify the owner and must be durable enough to resist the effects of the environmental
conditions to which they may be exposed.
National Pollutant Discharge Elimination System (NPDES)
Any of the items of this section that are lost overboard shall be recorded on the facility’s daily
operations report, as appropriate, and reported to the BSEE District Supervisor.
NPDES General Permit GMG290000 EPA region 6 Offshore District
NPDES- Water Sampling Requirements

• NPDES
• Chain Of Custody
• Security Seals
National Pollutant Discharge Elimination System (NPDES) Produced Water Analysis
1. Date of sample must be consistent on the reports
2. Time of sample in a 24 hour format
3. Location of where sample was taken (i.e. Skimmer, Sump tank, CPI)
4. Name of personnel taking the sample
5. Name of laboratory where the sample will be sent
6. Overboard water anaylsis monthly average is 29 PPM
Chain of Custody
1. Sample ID.
2. Collection sight of sample
3. Name of person taking sample
4. Date, time, type of sample, composite or grab
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5. Matrix, water soil, sludge or other. Overboard water samples will be water.
6. Type of container used, Glass, Plastic, Vial
7. Size/Volume of sample, Acid Included
8. Date of sample must be consistent on the reports
9. Name of laboratory where the sample will be sent
10. Location of where sample was taken (i.e. Skimmer, Sump tank, CPI)
Reporting Requirements
• Spills of more than one (1) barrel shall be confirmed in writing. Such written confirmation
shall be received by the BSEE District Supervisor by the fifteenth (15th) day, after the
spillage has been stopped.
• Read and understand the Oil Spill Response Plan (OSRP) Follow the chain of command as
per the OSRP, Do not hesitate to report and document all sheens, spills, produced water
sheens. You can be held libel through civil penalties if the reporting is not done in a timely
manner.
• Spills shall be reported orally within the following time limits:
• Within Twelve (12) hours, if spills are one (1) Barrel or less.
• Without delay if spills are more than one (1) Barrel to BSEE and National Response
Center (NRC) and make sure to follow Lessee environmental pollutant reporting
procedure.
• Lessees shall notify the responsible party, National Response Center (NRC) and the BSEE
District Supervisor of observed pollution resulting from operations other than those
conducted by the lessee.
• NRC National Response Center: http://www.nrc.uscg.mil/ or 800-424-8802
Inspection of Facilities
Drilling and production facilities shall be inspected daily or at intervals or prescribed by the
District Supervisor to determine if pollution is occurring. The prescribed method is when a
pollution matrix is performed by lessee, wavier applied for, and approved by the BSEE District
Supervisor. The pollution wavier will prescribe when visits are necessary. Manned facilities are
required to conduct pollution checks daily. Necessary maintenance or repairs shall be made
immediately.
Records of such all inspections and repairs shall be maintained at the facility or at the
nearby manned facility for 2 years.
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Subpart D - Oil and Gas Drilling Operations

Hydrogen Sulfide (H2S)
What precautions must I take when operating in an H2S area? You must take all necessary and
feasible precautions and measures to protect personnel from the toxic effects of H2S and to
mitigate damage to property and environment caused by H2S. You must follow the
requirements of this section when conducting drilling, well-completion/well-workover, and
production operations in zones with H2S present and when conducting operations in zones
where the presence of H2S is unknown. You do not need to follow these requirements when
operating in zones where the absence of H2S has been confirmed.
Follow your approved contingency plan. Definitions-Terms used in this section have the
following meanings:
- Facility means: A vessel, a structure, or an artificial island used for drilling, well-
completion, well-workover, and/or production operations.
- H2S absent means: Drilling, logging, coring, testing, or producing operations have
confirmed that absence of H2S in concentrations that could potentially result in
atmospheric concentrations of 20 PPM or more of H2S. Or drilling in the surrounding
areas and correlation of geological and seismic data with equivalent stratigraphic units
has confirmed an absence of H2S throughout the area to be drilled.
- H2S present means: those drilling, logging, coring, testing, or producing operations have
confirmed the presence of H2S in concentrations and volumes that could potentially
result in atmospheric concentrations of 20 PPM or more of H2S.
- H2S unknown: means the designation of the zone or geologic formation where neither
the presence nor absence of H2S has been confirmed.
- Well-control fluid means: Drilling mud and completion or workover fluid as appropriate
to the particular operation being conducted.
In order to classify an area for the presence of H2S you must request and obtain an approved
classification for the area from the Regional Supervisor before you begin operations.
Classifications are “H2S absent”, “H2S present”, or “H2S unknown”. Submit your request with
your application for permit to drill. Support your request with available information such as
geologic and geophysical data and correlations, well logs, formation tests, cores and analysis of
formation fluids; and submit a request for reclassification of a zone when additional data
indicate a different classification is needed.
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What do I do if the H2S operating conditions change?
If you encounter H2S that could potentially result in atmospheric concentrations of 20PPM or
more in areas not previously classified as having H2S present, you must immediately notify BSEE
and begin to follow requirements for areas with H2S present.
What are the requirements for conducting simultaneous operations?
When conducting any combination of drilling, well-completion, well-workover and production

operations simultaneously, you must follow the requirements in the section applicable to each
individual operation.
Requirements for submitting an H2S Contingency Plan
Before you begin operations, you must submit and H2S Contingency Plan to the District
Supervisor for approval. Do not begin operations before the District Supervisor approves your
plan. You must keep a copy of the approved plan in the field, and you must follow the plan at all
times.
Your plan must include: Safety procedures and rules that you will follow concerning equipment,
drills and smoking, training you provide for employees, contractors, and visitors, Job position
and title of the person responsible for the overall safety of personnel.
Your plan must also include: Other key positions, how these positions fit into your organization,
and what the functions, duties and the responsibilities of those job positions.
Actions that you will take when the concentration of H2S in the atmosphere reaches 20 PPM,
who will be responsible for those actions, and a description of the audible and visual alarms to
be activated, briefing areas where personnel will assemble during an H2S alert. You must have
at least two briefing areas on each facility and use the briefing area that is upwind of the H2S
source at any given time; Criteria you will use to decide when to evacuate the facility and
procedures you will use to safely evacuate all personnel form the facility be vessel, capsule, or
lifeboat. If you use helicopters during H2S alerts, describes the types of H2S emergencies during
which you consider the risk of helicopter activity to be acceptable and the precautions you will
take during the flights; Procedures you will use to safely position all vessels attendant to the
facility. Indicate where you will locate the vessels with respect to wind direction. Include the
distance from the facility and what procedures you will use to safely relocate the vessels in an
emergency; How you will provide protective-breathing equipment for all personnel, including
contractors and visitors; The agencies and facilities you will notify in case of a release of H2S
(that constitutes an emergency), how you will notify them, and their telephone numbers.
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Include all facilities that might be exposed to atmospheric concentrations of 20 PPM or more of
H2S.
The medical personnel and facilities you will use if needed, their addresses, and telephone
numbers; H2S detector locations in production facilities producing gas containing 20 PPM or
more of H2S. Include an “H2S Detector Location Drawing” showing: All vessels, flare outlets,
wellheads, and other equipment handling production containing H2S;
Approximate maximum concentration of H2S in the gas stream; and location of all H2S sensors
included in your contingency plan; Operational conditions when you expect to flare gas
containing H2S concentration, and duration for flaring;
Your assessment of the risks to personnel during flaring and what precautionary measures you
will take; Primary and alternate methods to ignite the flare and procedures for sustaining
ignition and monitoring the status of the flare (i.e., ignited or extinguished);
Procedures to shut off the gas to the flare in the even the flare are extinguished; Portable or
fixed sulphur dioxide (SO2)-detection system (s) you will use to determine SO2 concentration
and exposure hazard when H2S is burned; Increased monitoring and warning procedures you will
take when the SO2 concentration in the atmosphere reaches 2PPM; Personnel protection
measures or evacuation procedures you will initiate when the So2 concentration in the
atmosphere reaches 5PPM; Engineering controls to protect personnel from SO2; and any special
equipment procedures, or precautions you will use if you conduct any combination of drilling,
well-completion, well-workover, and production operations simultaneously.
H2S Training Program Certification

When and how often do employees need to be trained?
All operators and contract personnel must complete a documented H2S training program to
meet the requirements of this section before beginning work at the facility; and each year,
within 1 year after completion of the previous class.
What training documentation do I need? For each individual working on the platform, either:
You must have documentation of this training at the facility where the individual is employed; or
the employee must carry a training completion card. What training do I need to give to visitors
and employees previously trained on another facility? Trained employees or contractors
transferred from another facility must attend a supplemental briefing on your H2S equipment
and procedures before beginning duty at your facility;
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Visitors who will remain on your facility more than 24 hours must receive the training required
for employees as previously discussed and visitors who will depart before spending 24 hours on
the facility are exempt from the training required for employees, but they must, upon arrival,
complete a briefing that includes:
Information on the location and use of an assigned respirator; practice in donning and adjusting
the assigned respirator, information on the safe briefing areas, alarm system, and hazards of H2S
and SO2 and instructions on their responsibilities in the event of an H2S release. What training
must I provide to all other employees?
You must train all individuals on your facility on the: Hazards of H2S and SO2 and the provisions
for personnel safety contained in the H2S Contingency Plan; Proper use of safety equipment
which the employee may be required to use; location of protective breathing equipment, H2S
detectors and alarms, ventilation equipment, briefing areas, warning systems, evacuation
procedures, and the direction of prevailing winds; Restrictions and corrective measures
concerning beards, spectacles, and contact lenses in conformance with ANSI Z88.2; Basic first-aid
procedures applicable to victims of H2S exposure. During all drills and training sessions, you
must address procedures for rescue and first aid for H2S victims, the following apply: Location
of: The first-aid kit on the facility; resuscitators; and litter or other device on the facility; meaning
of all warning signals. Do I need to post safety information? You must prominently post safety
information on the facility and on vessels serving the facility (i.e. basic first aid, escape routes,
instructions for use of lifeboats, etc.).
H2S Drills
When and how often do I need to conduct drills on H2S safety discussions on the facility?
Conduct a drill for each person at the facility during normal duty hours at least once weekly
every 7-day period. The drills must consist of a dry-run performance of personnel activities
related to assigned jobs. At a safety meeting or other meetings of all personnel, discuss drill
performance, new H2S considerations at the facility, and other updated H2S information at least
monthly. What documentation do I need? You must keep records of attendance for: Drilling,
well-completion, and well-workover operations at the facility until operations are completed.
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Subpart E - Casing Management And Diagnostic System Information
30 CFR 250.415 requires a casing and cementing program installed and implemented during
drilling phase.
What is Sustained Casing Pressure SCP?
Sustained casing head pressure (SCP) is 1) a pressure measurable at the casing head of a casing
annulus that rebuilds when bled down, 2) not due solely to temperature fluctuations, and 3) not
a pressure that has been deliberately applied.
What is Unsustained Casing Pressure?
Unsustained casing pressure does not require a departure from the requirements of 30 CFR
250.517(c). This determination is made if either the only casing pressure on a well is self-
imposed, such as gas-lift pressure, gas or water injection pressure, or is entirely thermally
induced.
30 CFR 250.518 thru 30 CFR 250.531 regulations requires that when the well has been drilled
and completed a wellhead tree is installed, you must equip wells to monitor for casing pressure
according to the following chart:
If you . . . you must equip . . . so you can monitor . . .

(1) fixed the wellhead, all annuli (A, B, C, D, etc., annuli).
platform
wells,
(2) subsea the tubing head, the production casing annulus (A annulus).
wells,
(3) hybrid* the surface wellhead, all annuli at the surface (A and B riser annuli). If the
wells, production casing below the mudline and the
production casing riser above the mudline are
pressure isolated from each other, provisions must be
made to monitor the production casing below the
mudline for casing pressure.
*Characterized as a well drilled with a subsea wellhead and completed with a surface casing
head, a surface tubing head, a surface tubing hanger, and a surface christmas tree.
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What are the requirements for casing pressure management? 30 CFR 250.519
Once you install your wellhead, you must meet the casing pressure management
requirements of API RP 90 (as incorporated by reference in 250.198) and the requirements of
250.519 through 250.530. If there is a conflict between API RP 90 and the casing pressure
requirements of this subpart, you must follow the requirements of this subpart.
How often do I have to monitor for casing pressure? 30 CFR 250.520
You must monitor for casing pressure in your well according to the following table:
you must with a minimum one pressure

If you have . . .
monitor data point recorded per . . .
(a) fixed platform wells, monthly, month for each casing.
(b) subsea wells, continuously, day for the production casing.
continuously, day for each riser and/or the
(c) hybrid wells,
production casing.
(d) wells operating under a casing pressure daily, day for each casing.
request on a manned fixed platform,
(e) wells operating under a casing pressure weekly, week for each casing.
request on an unmanned fixed platform,
When do I have to perform a casing diagnostic test? 30 CFR 250.521
(a) You must perform a casing diagnostic test within 30 days after first observing or
imposing casing pressure according to the following table:
If you have a
you must perform a casing diagnostic test if . . .
. . .
(1) fixed the casing pressure is greater than 100 psig.
platform well,
(2) subsea well, the measurable casing pressure is greater than the external hydrostatic
pressure plus 100 psig measured at the subsea wellhead.
(3) hybrid well, a riser or the production casing pressure is greater than 100 psig measured at
the surface.
(b) You are exempt from performing a diagnostic pressure test for the production casing on
a well operating under active gas lift.
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How do I manage the thermal effects caused by initial production on a newly

completed or recompleted well? 30 CFR 250.522
A newly completed or recompleted well often has thermal casing pressure during initial
startup. Bleeding casing pressure during the startup process is considered a normal and
necessary operation to manage thermal casing pressure; therefore, you do not need to evaluate
these operations as a casing diagnostic test. After 30 days of continuous production, the initial
production startup operation is complete and you must perform casing diagnostic testing as
required in 250.520 and 250.522.
When do I have to repeat casing diagnostic testing? 30 CFR 250.523
Casing diagnostic testing must be repeated according to the following table:
When . . . you must repeat diagnostic testing . . .

(a) your casing pressure request approved term has immediately.
expired,
(b) your well, previously on gas lift, has been shut-in immediately on the production casing (A
or returned to flowing status without gas lift for annulus). The production casing (A annulus)
more than 180 days, of wells on active gas lift are exempt from
diagnostic testing.
(c) your casing pressure request becomes invalid, within 30 days.
(d) a casing or riser has an increase in pressure within 30 days.
greater than 200 psig over the previous casing
diagnostic test,
(e) after any corrective action has been taken to within 30 days.
remediate undesirable casing pressure, either as a
result of a casing pressure request denial or any
other action,
(f) your fixed platform well production casing (A once per year, not to exceed 12 months
annulus) has pressure exceeding 10 percent of its between tests.
minimum internal yield pressure (MIYP), except for
production casings on active gas lift,
(g) your fixed platform well's outer casing (B, C, D, once every 5 years, at a minimum.
etc., annuli) has a pressure exceeding 20 percent of
its MIYP,
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How long do I keep records of casing pressure and diagnostic tests? 30 CFR
250.524
Records of casing pressure and diagnostic tests must be kept at the field office nearest the well
for a minimum of 2 years. The last casing diagnostic test for each casing or riser must be
retained at the field office nearest the well until the well is abandoned.
When am I required to take action from my casing diagnostic test? 30 CFR

250.525
You must take action if you have any of the following conditions:
(a) Any fixed platform well with a casing pressure exceeding its maximum allowable
wellhead operating pressure (MAWOP);
(b) Any fixed platform well with a casing pressure that is greater than 100 psig and that
cannot bleed to 0 psig through a 1⁄2 -inch needle valve within 24 hours, or is not bled to 0 psig
during a casing diagnostic test;
(c) Any well that has demonstrated tubing/casing, tubing/riser, casing/casing, riser/casing,
or riser/riser communication;
(d) Any well that has sustained casing pressure (SCP) and is bled down to prevent it from
exceeding its MAWOP, except during initial startup operations described in §250.521;
(e) Any hybrid well with casing or riser pressure exceeding 100 psig; or
(f) Any subsea well with a casing pressure 100 psig greater than the external hydrostatic
pressure at the subsea wellhead.
What do I submit if my casing diagnostic test requires action? 30 CFR 250.526
Within 14 days after you perform a casing diagnostic test requiring action under 250.524:
You must submit and it must

either . . . to the appropriate . . . include . . . You must also . . .
(a) a notification District Manager and requirements submit an Application for Permit
of corrective copy the Regional under 250.526, to Modify or Corrective Action
action; or, Supervisor, Field Plan within 30 days of the
Operations, diagnostic test.
(b) a casing Regional Supervisor, Field requirements
pressure request, Operations, under 250.527.
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What must I include in my notification of corrective action? 30 CFR 250.527
The following information must be included in the notification of corrective action:
(a) Lessee or Operator name;
(b) Area name and OCS block number;
(c) Well name and API number; and
(d) Casing diagnostic test data.
What must I include in my casing pressure request? 30 CFR 250.528
The following information must be included in the casing pressure request:
(a) API number;
(b) Lease number;
(c) Area name and OCS block number;
(d) Well number;
(e) Company name and mailing address;
(f) All casing, riser, and tubing sizes, weights, grades, and MIYP;
(g) All casing/riser calculated MAWOPs;
(h) All casing/riser pre-bleed down pressures;
(i) Shut-in tubing pressure;
(j) Flowing tubing pressure;
(k) Date and the calculated daily production rate during last well test (oil, gas, basic
sediment, and water);
(l) Well status (shut-in, temporarily abandoned, producing, injecting, or gas lift);
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(m) Well type (dry tree, hybrid, or subsea);
(n) Date of diagnostic test;
(o) Well schematic;
(p) Water depth;
(q) Volumes and types of fluid bled from each casing or riser evaluated;
(r) Type of diagnostic test performed:
(1) Bleed down/buildup test;
(2) Shut-in the well and monitor the pressure drop test;
(3) Constant production rate and decrease the annular pressure test;
(4) Constant production rate and increase the annular pressure test;
(5) Change the production rate and monitor the casing pressure test; and
(6) Casing pressure and tubing pressure history plot;
(s) The casing diagnostic test data for all casing exceeding 100 psig;
(t) Associated shoe strengths for casing shoes exposed to annular fluids;
(u) Concentration of any H2S that may be present;
(v) Whether the structure on which the well is located is manned or unmanned;
(w) Additional comments; and
(x) Request date.
What are the terms of my casing pressure request? 30 CFR 250.529
Casing pressure requests are approved by the Regional Supervisor, Field Operations, for a
term to be determined by the Regional Supervisor on a case-by-case basis. The Regional
Supervisor may impose additional restrictions or requirements to allow continued operation of
the well.
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What if my casing pressure request is denied? 30 CFR 250.530
(a) If your casing pressure request is denied, then the operating company must submit plans
for corrective action to the respective District Manager within 30 days of receiving the denial.
The District Manager will establish a specific time period in which this corrective action will be
taken. You must notify the respective District Manager within 30 days after completion of your
corrected action.
(b) You must submit the casing diagnostic test data to the appropriate Regional Supervisor,
Field Operations, within 14 days of completion of the diagnostic test required under
§250.522(e).
When does my casing pressure request approval become invalid? 30 CFR

250.531
A casing pressure request becomes invalid when:
(a) The casing or riser pressure increases by 200 psig over the approved casing pressure
request pressure;
(b) The approved term ends;
(c) The well is worked-over, side-tracked, redrilled, recompleted, or acid stimulated;
(d) A different casing or riser on the same well requires a casing pressure request; or
(e) A well has more than one casing operating under a casing pressure request and one of
the casing pressure requests become invalid, then all casing pressure requests for that well
become invalid.
Subpart F – Oil & Gas Well – Workover Operations
ESD Station Location Information
• When well-workover operations are conducted on a well with the tree remove
• An emergency shutdown system (ESD) manually controlled station shall be installed near
the driller's console or well-servicing unit operator's work station except when there is
no other hydrocarbon-producing well or other hydrocarbon flow on the platform
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Diesel Engine, Insulation, Spark Arrestors, Air Intake Shut Down Devices
• Engine exhausts shall be equipped to comply with the insulation and personnel protection
requirements of API RP 14C, section 4.2c(4), 30 CFR 250.610, 30 CFR 250.803 (5)(i)
• Exhaust piping from diesel engines shall be equipped with spark arresters.
• All Diesel driven engines the air intakes shall be equipped with a device to shut-down the
diesel engine in the event of runaway.
• Diesel engines, which are continuously attended, shall be equipped with either remote
operated manual or automatic shutdown devices.
• Diesel engines, which are not continuously attended, shall be equipped with automatic
shutdown devices.
Subpart H - Oil and Gas Production Safety Systems
Subsurface Safety Devices (SSSV) (General)
All tubing installations open to hydrocarbon-bearing zones shall be equipped with subsurface
safety devices that will shut off the flow the well in the event of an emergency unless, after
application a justification, the well is determined by the BSEE District Supervisor to be incapable
of natural flowing. These devices may consist of a surface-controlled subsurface safety valve
(SCSSV), subsurface-controlled subsurface safety valve (SSCSV), an injection valve, a tubing plug,
or a tubing/annular subsurface safety device, and any associated safety valve lock or landing
nipple.
Specifications for SSSVs

Surface-controlled (SCSSV) and subsurface-controlled (SSCSV) SSSVs and safety valve locks and
landing nipples installed in the OCS shall conform to the requirements as previously discussed.
Surface-controlled (SCSSV) SSSVs: All tubing installations open to a hydrocarbon-bearing

zone which is capable of natural flow shall be equipped with a surface-controlled SSSV,
except as specified in this section. The surface controls may be located on the site or a remote
location. Wells not previously equipped with a surface-controlled (SCSSV) SSSV and wells in
which a surface-controlled SSSV has been replaced with a subsurface-controlled (SSCSV) SSSV in
accordance with this section, shall be equipped with a surface-controlled (SCSSV) SSSV when the
tube is first removed and reinstalled.
Subsurface-controlled (SSCSV) SSSVs: Wells may be equipped with subsurface-controlled SSSVs

in lieu of a surface-controlled SSSV provided the lessee demonstrates to the District Supervisor’s
satisfaction that one of the following criteria are met: Wells not previously equipped with
surface-controlled SSSVs shall be so equipped when the tubing is first removed and reinstalled.
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The subsurface-controlled SSSV is installed in wells completed from a single-well or multi-well
satellite caisson or seafloor completions, or the subsurface-controlled SSSV is installed in wells
with a surface-controlled SSSV that has become inoperable and cannot be repaired without
removal and reinstallation of the tubing.
Design, installation and operation of SSSVs.
The SSSVs shall be designed, installed, operated and maintained to ensure reliable operation.
The safety device shall be installed at a depth of 100 feet or more below the seafloor or
mud line.
When warranted by conditions such as permafrost, unstable bottom conditions hydrate

formation, or paraffin’s, an alternate setting depth of the subsurface safety device may be
approved by the District Supervisor.
Until a subsurface safety device is installed, the well shall be attended in the immediate vicinity
so that emergency actions may be taken while the well is open to flow. During testing and
inspection procedures, the well shall not be left unattended while open to production unless a
properly operating subsurface-safety device has been installed in the well. The well shall not be
open to flow while the subsurface safety device is removed, except when flowing of the will is
necessary for a particular operation such as cutting paraffin, bailing sand, or similar operations.
All SSSVs shall be inspected, installed maintained and tested in accordance with American
Petroleum Institute Recommended Practice 14B, Recommended Practice for Design,
Installation, and Operation of Subsurface Safety Valve Systems. Subsurface safety devices in
shut-in wells. New completions (perforated but not placed on production) and completions shut
in for a period of 6 months shall be equipped with either a pump-through-type tubing plug; a
surface-controlled SSSV, provided the surface control has been rendered inoperative; or an
injection valve capable of preventing backflow. The setting depth of the subsurface safety
device shall be approved by the District Supervisor on a case-by-case basis, when warranted by
conditions such as permafrost, unstable bottom conditions, hydrate formations, and paraffin.
Subsurface safety devices in injection wells: A surface-controlled SSSV or an injection valve

capable of preventing backflow shall be installed in an injection wells. This requirement is not
applicable if the District Supervisor concurs that the well is incapable of flowing. The lessee shall
verify the no-flow condition of the well annually.
Temporary removal for routine operations: Each wireline or pump down-retrievable subsurface
safety device may be removed, without further authorization or notice for a routine operation
which does not require the approval of a Form BSEE-124, Sundry Notices and Reports on Wells
for a period not to exceed 15 days. The well shall be identified by a sign on the wellhead stating
that the subsurface safety device has been removed.
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The removal of the subsurface safety device shall be noted in the records as required. If the
master valve is open, a trained person shall be in the immediate vicinity of the well to attend the
well so that emergency actions may be taken, if necessary. A platform well shall be monitored,
but a person need not remain in the well-bay area continuously if the master valve is closed.
If the well is on a satellite structure, it must be attended or a pump-through plug installed in the
tubing at least 100 feet below the mud line and the master valve closed, unless otherwise
approved by the District Supervisor.
The well shall not be allowed to flow while the subsurface safety device is removed, except
when the flowing the well in necessary for that particular operation. The provisions of this
paragraph are not applicable to the testing and inspection procedures previously covered.
Additional safety equipment:
All tubing installations in which a wireline or pumpdown retrievable subsurface safety device is
installed after the effective date of this subpart shall be equipped with a landing nipple with
flow couplings or other protective equipment above and below to provide for the settings of
the SSSV.
The control system for all surface-control system for all surface-controlled SSSVs shall be
an integral part of the platform Emergency Shutdown System (ESD). In addition to the
activation of the ESD by manual action on the platform, the system may be activated by a
signal from a remote location.
A schematic of the ESD system, which indicates the control functions of all safety devices for the
platforms, shall be maintained by the lessee on the platform or at the lessee’s field office
nearest the OCS facility or other. All ESD stations shall be noted on the facility station bill
Surface-controlled SSSVs (SCSSV) shall close in response to shut-in signals from the ESD
and in response to the fire loop or other fire detection devices. (TSE = ESD)
Emergency action: In the event of an emergency, such as an impending storm, any well not
equipped with a subsurface safety device and which is capable of natural flow shall have the
device properly installed as soon as possible with due consideration being given to personnel
safety.
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Subpart J Pipelines 30 CFR 250
DOI pipelines include:
• Producer-operated pipelines extending upstream (generally seaward) from each point on

the OCS at which operating responsibility transfers from a producing operator to a
transporting operator.
• Producer-operated pipelines connecting facilities on the OCS.
• Transporter-operated pipelines that the DOI and DOT have agreed are to be regulated as
DOI pipelines
• Producer-operated pipelines connecting facilities on the OCS.
• Transporter-operated pipelines that the DOI and DOT have agreed are to be regulated as
DOI pipelines
• Incoming pipelines (KAQ) shall be equipped with a FSV and a SDV immediately upon
boarding the platform.
• Departing pipelines (KAH) shall be equipped with a set of PSHLs to directly or indirectly
shut-in the platform.
• Crossing pipelines which do not receive production from the platform shall be equipped
with a SDV immediately upon boarding the platform. The SDV shall be operated by a set
of PSHLs on the departing pipeline and connected to the platform automatic and remote
emergency shut-in system.
NOTE: The lease operator shall ensure the proper installation, operation, and maintenance of
safety devices required on all incoming, departing, and crossing pipelines on the platform
DOT pipelines include
• Transporter-operated pipelines currently operated under DOT requirements.

• Transporter-operated pipelines that the DOI and DOT have agreed are to be regulated
under DOT requirements.
• Producer-operated pipelines downstream (generally shoreward) of the last valve of the
last production facility on the OCS that does not connect to a transporter-operated
pipeline on the OCS before crossing into state waters and that are regulated under 49
CFR parts 192 and 195. DOT pipelines include:
The best way to find out if a pipeline is DOI or DOT is to search the BOEM or BSEE web site
pipeline segment number to eliminate any confusion.
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• Lease term pipelines are those pipelines owned and operated by a lessee or operator and
are wholly contained within the boundaries of a single lease, unitized leases, or
contiguous (not cornering) leases of that lessee or operator.
• Out-of-service pipelines are those pipelines that have not been used to transport oil,
natural gas, sulfur, or produced water for more than 30 consecutive days.
Pipeline and Pipeline Rights-of-Way
Pipelines are the piping, risers, and appurtenances installed for the purpose of transporting oil,
gas, sulphur, and produced water. (Piping confined to a production platform or structure is
covered in Subpart H, Production Safety Systems, and is excluded from this subpart.)
Abandonment and out-of service requirements for DOI pipelines.
A pipeline may be abandoned in place if, in the opinion of the Regional Supervisor, it does not
constitute a hazard to navigation, commercial fishing operations, or unduly interfere with other
uses in the OCS.
Pipelines to be abandoned in place shall be flushed, filled with seawater, cut, and plugged with
the ends buried at least 3 feet. Pipelines abandoned by removal shall be pigged, unless the
Regional Supervisor determines that such procedure in not practical, and flushed with water
prior removal.
Pipelines taken out of service 1 Year or less must be isolated with a blind flange or a locked
block valve at each end of the pipeline. Pipelines taken out-of-service shall be blind flanged or
isolated with a closed block valve at each end.
Pipelines taken out-of-service for a period of more than 1 year shall be flushed and filled
with inhibited (chemically treated) seawater.
Pipelines taken out-of-service shall be returned to service within 5 years or be abandoned in

accordance with the requirements previously discussed..
Subpart K 30 CFR 250 Oil and Gas Production Rates
Flaring or venting gas and burning liquid hydrocarbons 30 CFR 250.1160
Lessee may flare or vent oil-well or gas-well gas without receiving prior approval from the BSEE
Regional Supervisor only in the following situations: When gas vapors are flared or vented in
small volumes from storage vessels or other low pressure production vessels and cannot be
economically recovered.
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Lessee may not flare or vent more than an average of 50 MCF per day during the calendar month
without BSEE Regional Supervisor approval.
During an equipment failure or to relieve system pressure the lessee must comply with the
following conditions: Lessees must not flare or vent gas/oil-well gas for more than 48
continuous hours unless the BSEE Regional Supervisor approves. The Regional Supervisor may
specify a limit of less than 48 hours to prevent air quality degradation.
Lessees must not flare or vent gas from a facility for more than 144 cumulative hours during
any calendar month unless the Regional Supervisor approves. Lessees must not flare or vent
gas-well gas beyond the time required to eliminate an emergency unless the Regional Supervisor
approves.
Facilities as per NTL No. 2011-N04 30 CFR 250.1163 that process an average of 2000 BOPD shall
have Flare Vent Meters installed with a 5% accuracy and calibrated annually or as manufacture
requires
During an equipment failure or to relieve system pressure the lessee must not flare or vent gas-
well gas for more than 2 continuous hours unless the BSEE Regional Supervisor approves
You must report and log all vented or flared gas
Well Testing 330 CFR 250.1151 Non Allocated Wells
A well-flow potential test on all new, recompleted, or reworked well completions within 30 days
of the date of first continuous production to be turned in to BSEE. (Office) within 15 days after
the end of the test period 30 CFR 250.1167
A non-allocated well (100% Owned) must have at least one well test during a calendar half-year
for each producing completion; this must be submitted to BSEE within 45 days after the end of
the calendar half-year. Well test must be tested for a minimum of (4) four hours, Verify that gas,
oil test meters have been calibrated as required.
Well Testing 330 CFR 250.11204 Allocated Wells
An allocated well (more than one investor) must have one well test completed once every 60
days unless the regional supervisor approves a different frequency
Well test must be tested for a minimum of (4) four hours, Verify that gas, oil test meters have
been calibrated as required.
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Subpart – L Oil and Gas Production Measurement, Surface

Commingling, and Security Liquid 30 CFR 250.1201
• Allocation meter - a meter used to determine the portion of hydrocarbons attributable to
one or more platforms, leases, units, or wells, in relation to the total production from a
royalty or allocation measurement point.
• Operating meter - a royalty or allocation meter that is used for gas or liquid hydrocarbon
measurement for any period during a calibration cycle
• Pressure base - the pressure at which gas volumes and quality are reported. The standard
pressure base is 14.73 psia.
• Prove - to determine (as in meter proving) the relationship between the volume passing
through a meter at one set of conditions and the indicated volume at those same
conditions.
• Royalty meter - a meter approved for the purpose of determining the volume of gas, oil,
or other components removed, saved, or sold from a Federal lease.
• Royalty tank - an approved tank in which liquid hydrocarbons are measured and upon
which royalty volumes are based.
• Run ticket - the invoice for liquid hydrocarbons measured at a royalty point.
• Sales meter - a meter at which custody transfer takes place (not necessarily a royalty
meter).
• Seal - a device or approved method used to prevent tampering with royalty measurement
components
What are the requirements for run tickets? You must:
• For royalty meters, ensure that the run tickets clearly identify all observed data, all
correction factors not included in the meter factor, and the net standard volume.
• For royalty tanks, ensure that the run tickets clearly identify all observed data, all
applicable correction factors, on/off seal numbers, and the net standard volume.
• Pull a run ticket at the beginning of the month and immediately after establishing a new
monthly meter factor or a malfunction meter factor.
• Send all run tickets for royalty meters and tanks to the Regional Supervisor within 15 days
after the end of the month.
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Proving Meters:
Oil Meters
What are the requirements for oil meter calibrations? You Must:
• Prove each operating oil royalty meter to determine the meter factor monthly, but the
time between meter factor determinations must not exceed 42 days
• Prove operating allocation oil meters monthly if they measure 50 or more barrels per day
per meter the previous month.
• Prove operating allocation oil meters quarterly if they measure less than 50 barrels per
day per meter the previous month.
• Keep a copy of the proving reports at the field location for 2 years
Gas meters
What are the requirements for gas meter calibrations? You must:
• Verify and calibrate gas operating meters monthly, but do not exceed 42 days between
verifications and calibrations.
• Calibrate each meter by using the manufacturer's specifications;
• Conduct calibrations as close as possible to the average hourly rate of flow since the last
calibration;
• Retain calibration reports at the field location for 2 years, and send the reports to the
Regional Supervisor upon request;
-
There is a requirement to post or stencil a sign at each royalty or inventory tank which is
used in the royalty (Oil Sales) determination process.
• The sign must contain the name of the facility operator: ABC
• The size of the royalty storage tank in barrels : 500 BLBS
• The tank identification number as per approved safe chart: ABJ-1002
Seal the following components of liquid hydrocarbon royalty meter installations to ensure
that tampering cannot occur without destroying the seal:
• Meter component connections from the base of the meter up to and including the
register;
• Sampling systems including packing device, fittings, sight glass, and container lid;
• Temperature and gravity compensation device components;
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• All valves on lines leaving a royalty or inventory storage tank, including load-out line
valves, drain-line valves, and connection-line valves between royalty and non-royalty
tanks; and
• Seal all bypass valves of gas royalty and allocation meters.
• Number and track the seals and keep the records at the field location for at least 2 years;
and make the records of seals available for BSEE inspection.
• Prior to any seal removal, transporter permission shall be obtained, granted, documented
and placed on file
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Subpart N – Civil Penalties

• Violations that you do not correct within the period BSEE grants;
• Violations that determines that may constitute, or constituted, a threat of serious,
irreparable, or immediate harm or damage to life (including fish and other aquatic life),
property, any mineral deposit, or the marine, coastal, or human environment
• Violations of the oil spill financial responsibility requirements at 30 CFR part 253.
May the United States criminally prosecute me for violations under Federal oil and gas
leases?
• If you commit an act for which a civil penalty is provided at 30 U.S.C. 1719(d) and §
250.1460(b), the United States may pursue criminal penalties as provided at 30 U.S.C.
1720, in addition to any authority for prosecution under other statutes.
• Examples: P-103 Pinc for Not conducting OOS flagging, or monitoring
• PINC = Potential Incident of Non-Compliance : A list of guidelines or checklist used by
BSEE Inspectors to pursue safe operations in OCS waters
Subpart O T-2 References: Training Requirements

30 CFR 250.1500 Through 30 CFR 250.1510
How often must I train my employees? 30 CFR 250.1506
The leesee determines the frequency of the training they provide employees.
You must do all of the following:
• Provide periodic training to ensure that employees maintain understanding of, and
competency in, well control or production safety practices;
• Establish procedures to verify adequate retention of the knowledge and skills that
employees need to perform their assigned well control or production safety duties; and
• Ensure that your contractors' training programs provide for periodic training and
verification of well control or production safety knowledge and skills.
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Subpart-O
(PSST)
Training
Module
5
Requirements of 30 CFR 250
Subpart H, Section 803
& API RP14C
Pressure Settings & Test Tolerances

Sensors Support System
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Pressure Settings & Test Tolerances

Pressure Safety Valves (PSV/Relief Valves)
(As Per Requirements of 30 CFR 250, Subpart H, Section 803 & API RP14C)
A. Pressure Safety Valves (PSV, Relief Valves): Pressure Settings

Set the PSV at the Maximum Allowable Working Pressure (MAWP) or Less if required by a
downstream component of the individual process component or equipment item.
B. PSV Test Tolerances are: + or – 2 PSI for PSV set pressures less than or equal to 70 PSI.
Example 1: Low Pressure Production Separator: MAWP of 70 PSI.

Pressure Setting Required: 66 PSI (Set PSV at this Pressure).
PSV Pressure Setting Test Tolerances: 64 PSI (for – 2 PSI) Low Side
68 PSI (for + 2 PSI) High Side

Pressure Setting Required: 50 PSI (Set PSV at this Pressure.)
PSV Pressure Setting Test Tolerances: 48 PSI (for – 2 PSI) Low Side
52 PSI (for + 2 PSI) High Side
C. Test Tolerances are: + or – 3% for PSV set pressures greater than 70 PSI
Example 3: High Pressure Production Separator: MAWP of 1440 PSI.

Pressure Setting Required: 1440 PSI (Set at this Pressure).
PSV Pressure Setting Test Tolerances: 1,397 PSI (for – 3% of MAWP) Low Side
1,483 PSI (for + 3% of MAWP) High Side
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Pressure Setting Required: 125 PSI (Set at this Pressure).
PSV Pressure Setting 125 psi Test Tolerances: 121 PSI (for – 3% of MAWP) Low Side
129 PSI (for + 3% of MAWP) High Side
Important Notes:
At no time can the Pressure Setting of the PSV be set NO greater than the MAWP (Maximum
Allowable Working Pressure) of the process vessel or individual component. However, the PSV
can relieve or exhaust pressure at the test tolerances ranges shown above during testing as per
API 14C.
If the PSV relieves or discharges pressure above or below the specific test tolerances (during
formal inspection by the examining BSEE inspector or representative for pressure ranges as
described in Sections B & C) a non-compliance (P-451) will be issued for the Out-of-Tolerance
test results.
Pressure Safety Valves (PSV) that are out-of-tolerance (during testing) have to be “reset” at the
proper Pressure Setting (no greater than the MAWP as defined above) and the test results must
be documented and placed on file for two years
All PSV’s shall have full ported, manual isolation valve between them and the pressure source
and the valve shall be of a lockable nature. It shall be locked open during normal operating
service
Replacement PSV’s shall be the same inlet and outlet sizes or like kind. Settings can vary as per
operational requirement
All PSV’s outlets shall be vented to a safe location so has not to cause injury or any explosive gas
atmospheres
Note: Even though API RP 14C gives a PSV test tolerance, Depending on which BSEE district you
are working under, Sometimes the BSEE inspector test tolerance point of view is where he will
not accept the PSV high side test tolerance due to being over the MAWP. Recommend PSV
setting be 20 psi below MAWP for minimal tolerance spread
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PSV & PSHL is always sensing at the highest portion of the Gas Section
• Pressure Safety High Low Pressure Settings

Pressure Safety High (PSH) & Pressure Safety Low (PSL)
(As Per Requirements of 30 CFR 250.803 & API RP14C)
Determining the HOP (Highest Operating Pressure) & the LOP (Lowest Operating Pressure) is
done by using a “Pressure Chart Recorder” (Range Chart) 30 CFR 250.803 (b) (iii) for a minimum
duration of 4 hours
PLC Chart and Paper Range Chart Below

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Range Chart Data Entry Instructions
• Verify the range recorder has been calibrated and also has the correct spring range installed
with a functional writing pen black or blue...
• You can use like the previous example a Scada Chart or a regular Barton recorder paper type
chart. Just verify it has the correct spring range on paper range chart
• The name of the Person performing the pressure setting recording
• Component Name Description - CHM300 2st Stage Compressor
• Platform ID – Note the Platform ID on range chart SP78A
• Component ID - Note on the range chart the approved Safe Chart BSEE ID - CZZ-600
• Chart Date - On Date and when chart is completed Date Chart Off
• The range chart requires a minimum of four (4) hours of run time. Note: that if the range
chart goes over 24 hours on the same chart the recording will be voided. BSEE will not let you
use this chart.
• Time – Note on the range chart the start time and the stop time
• Spring range – Note the spring range on the chart
• When the range chart is completed note by marking the HOP (High Operating pressure) and
the LOP (Low Operating Pressure) Write down these pressures on the range chart
• You cannot use spikes for pressure settings look closely for any movement that has an angle
to it.
• Calculate the PSH +15% or 5% under the PSV setting and note on the range chart
• Calculate the PSL – 15% and note on the range chart
A: Pressure Safety High (PSH) Process Vessel Pressure Settings
PSH: The High Pressure Setting must be + 15% or 5 PSI (use the greater of these two values)
above the Process Vessel’s Highest Operating Pressure. The “Highest Operating
Pressure” means the normal operating high operating range (highest pressure indicated)
as determined by a “Pressure Chart Recorder” that records the pressure for a minimum of
4 continuous hours. (P-100)
&
The High Pressure (PSH) Setting must also be 5% or 5 PSI less than (<) the Pressure
Safety Valve’s (PSV) Pressure Setting.
Example 1.: Low Pressure Production Separator – MAWP = 125 PSI

Highest Operating Pressure (Chart Recorded): 90 PSI
(PSV Pressure Setting = 125 PSI)
Pressure Safety High - Pressure Setting:

103 PSI (90 x 1.15 (+15%) = 103.5psi)
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Note: The High Pressure Setting (PSH) should always be “rounded down.” The number
103.5 is rounded off to 103 PSI. BSEE does not recognize decimal values only “whole”
numbers. Basically just drop the decimal point and leave the whole number alone on the
high side.
Example 2.: High Pressure - Bulk Separator: MAWP = 1440 PSI

Pressure Safety High - Setting: (1020 PSI x 1.15 (+15%) = 1173 psi)
Example 3. Glycol Contact Tower: MAWP = 1440 PSI

Pressure Safety High - Pressure Setting = 1403 PSI (1220 X 1.15 (+15%) = 1403 psi)
Pressure Safety High - Pressure Setting: ** 1368 PSI

(1440 - 5% - = 1368) See Note ** next.
Note: ** The Pressure Safety High (High Sensor) Pressure Setting must be 5% below
the PSV Pressure Setting of 1440 PSI. (1220 PSI x 15% + = 1403 PSI). Therefore, the
PSH Pressure Setting of 1403 PSI (which is 15% above the Highest Operating Pressure)
cannot be used, since it is of greater value than the –5% below the compliance
requirement (1440 + 5% - = 1368 PSI) of the PSV Pressure Setting of 1440 PSI.
Why the -5% PSH setting below the PSV set pressure?
- Setting the Pressure Safety High (PSH) at the 5% or 5 psi whichever is closet to
below the PSV set pressure is to ensure that the pressure source is shut in before
the pressure safety valve activates.
- Remember: Always calculate the Highest PSH setting as per the HOP on Range
Chart, After calculating the HOP PSH setting
- Next Using the PSV rule Always check and use the (– Minus) 5% under the PSV
setting as the highest setting you can set the PSH at.
- Always double check this number
B. Pressure Safety Low (PSL) Process Vessel Pressure Settings
PSL: The Low Pressure (PSL) Setting must be - 15% or 5 PSI (use the greater of these
two values) below the Vessel’s Lowest Operating Pressure. The “Lowest Operating
Pressure” (LOP) means the normal low operating range as determined (indicated) by a
“Pressure Chart Recorder” that records the pressure for a minimum of 4 continuous hours.
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Example 1 Low Pressure Production Separator - MAWP = 125 PSI.

Lowest Operating Pressure (Chart Recorded): 70 PSI
Pressure Safety Low Setting = 60 PSI (70 x 15% - = 59.5)
Note: * The Low Pressure Setting (PSL) should always be “rounded up.” The number 59.5 is
rounded off and up to 60 PSI. As previously stated, BSEE does not recognize decimal values
only “whole” numbers.
Just drop the decimal side and add one number to last whole number for the low side.
Example 2: High Pressure Bulk Separator: MAWP = 1440 PSI.

Lowest Operating Pressure (Chart Recorded): 950 PSI
Pressure Safety Low Setting = 808 PSI (950 x .85 (-15%) = 808 psi)
Example 3: Glycol Contact Tower: MAWP = 1440 PSI.

Lowest Operating Pressure (Chart recorded) 1130 PSI
Pressure Safety Low Setting: 961 PSI (1130 x .85 (-15%) = 961 psi)
Example 4: Treater: MAWP = 50 PSI

Lowest Operating Pressure: 20 PSI
Pressure Safety Low Setting: 15 PSI (20 – 5 PSI = 15 psi)
C. Pressure Safety High (PSH) Offshore Wells Flow line Pressure Settings
PSH: The High Pressure Setting must be + 15% or 5 PSI (use the greater of these two values)
above the Well Flow Line’s highest Operating Pressure since there is no PSV Installed. The
“Highest Operating Pressure” (HOP) means the normal high operating range as determined
(indicated) by a “Pressure Chart Recorder” (Range Chart) that records the pressure for a
minimum of 4 continuous hours.
&
When there is a requirement for the top side limiting factor and no PSV possibility installed,
operators shall use the Shut-in Tubing Pressure (STIP) or the Gas Lift Supply Pressure whichever
is the highest (in all cases).
The High Pressure (PSH) Setting must also be 5% or 5 PSI (which ever of the two values is
greater) less than the Shut-in Tubing Pressure (STIP) or the Gas Lift Supply Pressure (in all cases).
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Pressure Safety High (PSH) for Offshore Wells Flow line Pressure Settings - Example
Problems
Example 1. Well A14D, FA2 Flow line Segment

MAWP: 2160 PSI, SITP: 3800 PSI
Highest Operating Pressure: 1830 PSI
Pressure Safety High Setting: 2052 PSI (2160 MAWP x .95 (-5%) = 2052 psi)
Pressure Safety High Setting: 1830 PSI (1830 x 1.15% (+15%) = 2104 psi)
2104 psi is greater than the 5% requirement 2052 psi so the under 5% (2104) must be
used
Example 2. Well: A14, FA1 Flow line Segment

MAWP: 5000 PSI, SITP = 2700 PSI
Highest Operating Pressure Recorded: 2300 PSI X 1.15 (+15%) = 2645
* Pressure Safety High Setting: 2565 PSI (2700 x 5% - = 2565 psi)
Note: According to API RP14C, SAC Reference Table A.1 a2, the PSH is not required on Flow
line Segment FA1, since the Pipe Segment’s MAWP of 5,000 PSI is greater than the Well’s STIP
of 2,700 PSI. However, please note that a PSH is required (has to be installed) on final flow
line Segment FA2.
D. Pressure Safety Low (PSL) Offshore Wells Flow line Pressure Settings
PSL: The Low Pressure Setting must be - 15% or 5 PSI (use the greater of
these two values) below the Flow line’s Lowest Operating Pressure (LOP).
The “Lowest Operating Pressure” means the normal low operating range as determined or
indicated by a “chart recorder, range chart” that records the pressure for a minimum of 4
continuous hours.
Example 1. Well: A14D, FA2 Flow line Segment

Pressure Safety Low Setting: 1462 PSI (1720 X .85 (-15%) = 1462 psi)
Example 2. Well: A14, FA1 Flow line Segment

Pressure Safety Low Setting: 1666 PSI (1960 X .85 (-15%) = 1666 psi).
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Example 3: Well: A12, FA1 Flow line Segment

MAWP: 2,000 PSI, SITP: 600 PSI
Highest Operating Pressure: 500 PSI
Pressure Safety High Setting: 570 PSI (600 PSI x 5% - = 570 PSI).
(500 PSI x 15% + = 575 PSI)
This Pressure Setting is not to be used since it is greater than the –5 % Shut-In Tubing
Pressure requirement of 570 PSI).
Pressure Safety Low Setting: 340 PSI (400 PSI x 15% - = 340 PSI).
• Pressure Safety High Low (PSHL) – Set at 15% or 5 PSI (whichever is greater) below
the Highest or Lowest Operating Pressure (HLOP).
• Examples: Using the 5 PSI Rule
• Note: Using the magic number of 33, any pressure settings less than 33 psi would
fall under the rule using the 5 psi high or low setting or tolerance when performing
PSHL calculations only
• 32 + 15% = 36 psi
• 32 + 5 psi = 37 psi
• HOP = 32 psi what is the PSH Setting?
• 37 PSI Why? (32 – 36 = 4 PSI), (32 + 5 PSI = 37)
• Which one is greater, 37 PSI of course, Use the 37 PSI
• LOP = 18 PSI what is the PSL Setting?
• 18 - 15% = 16 PSI, 18 - 5 PSI = 13 PSI which is greater?
• LOP = 18 psi what is the PSL Setting? 13 PSI
Test Tolerances & Additional Notes
Pressure Safety High (PSH) & Low (PSL) Sensors

PSHL Pressure Setting Tolerances for a Pressure Setting greater than 5 PSI is a plus (+) or
minus (-) 5 Percent (%) or 5 PSI whichever is greater. However, the “trip” (test response)
pressure shall never exceed the pressure rating of the process equipment or component. A
PSHL (Pilot) assembly with a Pressure Setting of 5 PSI or less must function properly within the
service range for which it is installed.
Important Notes: Permission must be requested and obtained from the district BSEE
representative to set a Pressure Sensor (Pilot) below 5 PSI.
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Pressure Safety High & Low (PSH & PSL) Sensors (Pilots) that are out-of-tolerance (during
testing) have to be “reset” at the proper Pressure Setting (no greater than the Pressure
Setting value as defined previously) and the all test results must be documented.
• Test Tolerance Example:
Example A.: Required PSH Pressure Setting of 1,173 PSI

Test Tolerance Range: 1231 - 1115
This is the acceptable deviation or variation amount (for test purposes only!).
(+ 5% = 1,231 PSI by multiplying 1.05 x 1,173 (+5%) = 1,231 psi)

(- 5% = 1,115 PSI by multiplying .95 x 1,173 (-5%) = 1,115 psi)
Example B.: Required PSL Pressure Setting of 808 PSI

Test Tolerance Range: 848 - 768 PSI
(+ 5% = 848 PSI by multiplying 1.05 x 808 (+5%) = 848 PSI)

(- 5% = 768 PSI by multiplying .95 x 808 (-5%) = 768 PSI)
What is Dead Band?
Dead Band is described as the range where a pilot trips out of service to where it is able to reset
or return to service. A Sensor regains output pressure whenever the dead-band range is
surpassed
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Subpart-O
(PSST)
Training
Module
6
Additional Production Systems Requirements
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Addition Production Safety Systems

All shutdown devices, valves, and pressure sensors shall function in a manual reset mode.
Sensors with integral automatic reset shall be equipped with an appropriate device to
override the automatic reset mode Example (Spring Loaded manual reset pin).
All pressure sensors shall be equipped to permit testing with an external pressure source
Pressure and fired vessels. CFR 250.198 API RP 510
Pressure and fired vessels must be designed, fabricated, and code stamped in accordance with
the applicable provisions of Sections I, IV, and VIII of the American Society of Mechanical
Engineers (ASME) Boiler and Pressure Vessel Code. Pressure and fired vessels must have
maintenance inspection, rating, repair, and alteration performed in accordance with the
applicable provisions of API Pressure Vessel Inspections Code: In-Service Inspection, Rating,
Repair, and Alteration, API 510 (except Sections 5.8 and 9.5) (incorporated by reference as
specified in §250.198.
An ASME identification plate shall be permanently affixed to the vessel
If the ID plate is not attached the vessel must be taken out of service until another tag is
acquired or vessel recertified
ESD: CFR 250.503 CFR 250.603 (Work-Over ESD Station)
The ESD shall conform to the requirements of Appendix C, section C1, of the API RP 14C, and the
following:
• The manually operated ESD valve(s) shall be quick opening and non-restricted to enable
the rapid actuation of the shutdown system.
• Only ESD stations at the boat landing may utilize a loop of breakable synthetic tubing in
lieu of a valve.
• Closure of the SSV shall not exceed 45 seconds after automatic detection of an abnormal
condition or actuation of an ESD.
• The surface-controlled SSSV shall close in not more than 2 minutes after the shut-in
signal has closed the SSV. Design-delay closure time greater than 2 minutes shall be
justified by the lessee based on the individual wells mechanical/ production characteristic
and be approved by the BSEE District Supervisor.
• A schematic of the ESD system, which indicates the control functions of all safety devices
for the platforms, shall be maintained by the lessee on the platform or at the lessee’s
field office nearest the OCS facility or other location conveniently available to the District
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Supervisor, Also facility station bill
• When well-work over operations are conducted on a well with the tree removed, an
emergency shutdown system (ESD) manually controlled station shall be installed near the
driller's console or well-servicing unit operator's work station, except when there is no
other hydrocarbon-producing well or other hydrocarbon flow on the platform.
Engines: 30 CFR 250.803 API 14C 4.2.44
• Engine exhausts shall be equipped to comply with the insulation and personnel
protection requirements of API RP 14C, section 4.2c (4). Exhaust piping from diesel
engines shall be equipped with spark arresters.
• All Diesel driven engines the air intakes shall be equipped with a device to shut-down the
diesel engine in the event of runaway. Diesel engines, which are continuously attended,
shall be equipped with either remote operated manual or automatic shutdown devices.
Diesel engines, which are not continuously attended, shall be equipped with automatic
shutdown devices.
Glycol Dehydration Units.

A pressure relief system or an adequate vent shall be installed on the glycol regenerator
(Reboiler), which will prevent over pressurization. The discharge of the relief valve (PSV)
shall be vented in a safe and non-hazardous manner.
Gas Compressors: API 14C A-4 and A-8

Compressor installations shall be equipped with the following protective equipment as
required in API RP 14C, sections A4 and A8.
• A pressure safety high (PSH), a pressure safety low (PSL), a pressure safety valve (PSV),
and an LSL to protect each inter-stage and suction scrubber.
• A temperature safety high (TSH) on each compressor discharge cylinder.
• The PSH and PSL shut-in sensors and LSH shut-in controls protecting compressor suction
and inter-stage scrubbers shall be designed to actuate automatic shutdown valve SDV
located in each compressor suction and fuel gas line so that the compressor unit and the
associated vessels can be isolated from all input sources. All automatic SDV installed in
compressor suction and fuel gas piping shall also be actuated by the shutdown of the
prime mover.
• Unless otherwise approved by the District Supervisor, gas well gas affected by the closure
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of the automatic SDV on compressor suction shall be diverted to the pipeline or shut in at
the wellhead.
• An automatic blow-down valve (BDV) is required on the discharge line of all compressor
installations of 1,000 horsepower (746 kilowatts) or greater.
Firefighting Systems CFR 250.803 API 14C C.1.2

• A firewater system consisting of rigid pipe with fire hose stations or fixed firewater
monitors shall be installed on all facilities. The firewater system shall be installed to
provide needed protection in all areas where production handling equipment is located.
A fixed water spray system shall be installed in enclosed well bay areas where
hydrocarbon vapors may accumulate. A fire water system is required on all manned
facilities
• Fuel or power for firewater pump drivers shall be available for at least 30 minutes of run
time during a platform shut-in. (Diesel Or Natural Gas Powered)
• A firefighting system using chemicals may be used in lieu of a water system if the BSEE
District Supervisor determines that the use of a chemical system provides equivalent fire-
protection control. Example (Unmanned facilities, Small unmanned facilities)
• A diagram of the firefighting system showing the location of all firefighting equipment
shall be posted in a prominent place on the facility or structure
Fire and Gas Detection System CFR 250.803 API 14C C.1.2
• Fire (flame, heat, or smoke) sensors shall be installed in all enclosed classified areas. Gas
sensors shall be installed in all inadequately ventilated, enclosed classified areas.
• Adequate ventilation is defined as ventilation which is sufficient to prevent accumulation

of significant quantities of vapor-air mixture in concentrations over 25 percent of the
lower explosive limit (LEL). One approved method of providing adequate ventilation is a
change of air volume each 5 minutes or I cubic foot of air volume per square foot of solid
floor area, whichever is greater. Enclosed areas (e.g., buildings, living quarters, or
doghouses) are defined as those areas confined on more than four of their six possible
sides by walls, floors, or ceiling more restrictive to air flow than grating or fixed open
louvers and of sufficient size to all entry of personnel.
• Living quarters and doghouses does not contain a gas source and not located in a
classified area, does not require a gas detection system installed.
• A classified area is an area classified Class 1, Group D, Division 1 or 2, following the

guidelines of API RP 500.
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• All detection systems shall be capable of continuous monitoring. Fire detection systems
and portions of combustible gas detection systems related to the higher gas
concentration levels shall be of the manual reset type.
• A fuel-gas odorant or an automatic gas-detection and alarm system is required in

enclosed, continuously manned areas of the facility, which are provided with fuel gas.
• Living quarters and doghouses not containing a gas source and not located in a classified
area do not require a gas detection system.
• All Fire and Gas detection systems shall be capable of continuous monitoring. 365 24/7
• Fire detection systems and portions of combustible gas detection systems related to the
higher gas concentration levels shall be of the manual reset type (60%)
• Combustible gas-detection systems related to the lower gas-concentration level may be

of the automatic-reset type (25%)
• The BSEE District Supervisor may require the installation and maintenance of a gas
detector or alarm in any potentially hazardous area.
• Fire-and gas-detection systems shall be an approved typed, designed and installed in

accordance with API RP 14C, API RP 14G, and API RP 14F API RP 14FZ, Design and
Installation of Electrical Systems for Offshore Production Platforms.
• When conducting quarterly Gas Detection and Fire Fighting inspections, Verify that the
power systems will last a minimum at least 8 hours.
• Verify that a total platform shut down via the 60% fire and gas detection system is
conducted at least once a year.
Fire and Gas Detection System (TSE) 30 CFR 250.804 (a) (9)
• Clarification: All BSEE Districts require the (TSE) Fusible Plugs system to be tested
annually (as a minimum) for proper operation and control response. However according
to requirements of 30 CFR 250.804 (a) (9):
• All fire (flame, heat, or smoke) detection systems shall be tested for operation and or
recalibrated every 3 months (quarterly) provided that testing can be performed in a
nondestructive manner.“
• Some BSEE Districts enforce this requirement and some other districts enforce the annual
testing frequency policy. Check Lessee policy on TSE testing. Most electronic monthly
inspection programs has this inspection requirement installed.
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• Note: ESD and TSE activation testing is a required two separate test activations.
Electrical Equipment and Codes CFR 250.114

All electrical installations shall be made in accordance with Design and Installation of
Electrical Systems for Offshore Production Platforms except when not applicable
• API RP 14-F Designed, Installation, and Maintenance of electrical systems

• API RP 14FZ Design, Installation and Maintenance of Classified Zones
• API RP 14G Fire Prevention and Control on Production Platforms
• API RP 500 Classification Areas on Production Platforms
• API RP 505 Zones Classification Areas on Production Platforms
• API RP 14J Design and Hazard Analysis
Electrical equipment and systems shall be designed, installed, and maintained in
accordance with the requirements in Sec. 250.114 of this part.
Protection from ignition by electrical sources should be provided by designing and

maintaining electrical equipment in accordance with API Recommended Practice 14F or
other Applicable standards, and by classification of platform areas according to API
Recommended Practice 500 & 505. API Recommended Practice 14F defines criteria for
electrical equipment and wiring methods that can be used safely in classified and
unclassified areas on offshore production platforms.
API Recommended Practice 500 presents methods for classifying areas surrounding
drilling rigs and production facilities on land and on marine fixed and mobile platforms for
safe installation of electrical equipment.
Erosion
A program of erosion control shall be in effect for wells or fields having a history of sand
production. The erosion-control program may include sand probes, X-ray, ultrasonic, or
other satisfactory monitoring methods. Records by lease, indicating the wells which have
erosion control programs in effect and the results of the programs, shall be maintained by
the lessee for a period of 2 years and shall be made available to BSEE upon request.
General Platform Operations

• 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.
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• 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 back
in service. Any surface or subsurface devices which are temporarily out of service
shall be flagged.
• 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:
• Automatic fail-close SSV’s on wellhead assemblies, and
• The PSH and PSL shut-in sensors in flow-lines from wells.
B. 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.
C. All open-ended lines connected to producing facilities and wells shall be plugged or blind-
flanged, except those lines designed to be open-ended such as flare or vent lines.
Personnel Protection (from Hot Surface Contact) API PR 14 C 4.2.4.4

Protection must be provided anywhere that can be accidental contact by personnel within the
normal work or walk areas with any hot surface component in excess of 160 degrees F.
This protection can include but is not to be limited to: Insulation, Guards, Barriers and/or
Signs. Some mechanical components such as turbochargers, exhaust manifolds, compressor
heads, expansion bottles, and the like (including associated piping) are exceptions; in these
cases, warning signs are acceptable.
Any surface with a temperature in excess of 400°F (204°C) should be protected from exposure to
hydrocarbon liquids due to spillage or leakage.
Surfaces with a temperature in excess of 725°F (385°C) (approximately 80 percent of the ignition
temperature of natural gas) should be protected from exposure to accumulations of
combustible gases and vapors. Methods of protection can be insulation, barriers, water cooling,
etc. However, if such surfaces on permanent or portable equipment are in an area classified by
API Recommended Practice 500, they should be insulated.
Some mechanical components such as turbochargers, exhaust manifolds and the like (including
associated piping) that cannot be insulated without causing mechanical failure should be
protected by
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Subpart-O
(PSST)
Training
Module
7
Safety Device Test Frequency
Leakage Allowance Rates
ESD Response Time
Test Records (Record Keeping)
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Leakage Rates (Allowance during Testing)

An allowable leakage rate of 5 CFM of gas and or 200 CCM liquid is permissible or acceptable
for the safety devices listed next:
- Sub Surface Safety Valves (SSSV) which includes

- SCSSV
- SSCSV
- Tubing Plug
- Injection Valve.
- FSV (Flow Safety Valves) (Flowlines FSV Tested Only)
- SDV (Shutdown Valve) Operational Test Only
An allowable leakage rate of 15 CFM of gas and 400 CCM liquid is permissible or acceptable for
the safety devices listed next as per NTL 2009-G36
- USV (Underwater Safety Valve)
• Zero Leakage Tolerance when not used with BSDV
- The SSV (Surface Safety Valve on dry tree wellhead)

- BSDV (Boarding Shut Down Valve when designated and used in lieu of the
monthly USV testing. NTL-2009-G36
1. All of the SCSSVs must close within two (2) minutes after the last SSV has closed.
Example: An ESD valve is pulled or actuation, the last SSV closes within 29 seconds. What is the
total cumulative time limit allowed for the SCSSV to close from pulling the ESD Valve? Answer:
The SCSSV must close within a total time limit of 2 minutes and 29 seconds.
• Safety Device Test Frequency
• Daily (1 Day)
- Pollution Inspection
• Weekly (7Days)
- Fire Water Pumps Test Run (Two Hose Open Min 75 psi)
• Monthly (30 Days)

- PSHL
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- LSHL
- ESD Total Shut Down Test
- ESD Stations for Operation
- FSV (Wellhead Flow line Only)
- SSV
- SDV (Operational Ability Only)
- BSDV (used in Lieu of USV)
• Quarterly (90 Days)

- ASH
- OSH
- SO2
- YSH
- USH
- TSE
- USV as Per NTL 2009 G-36
- PSHL (Electronic)
- LSHL (Electronic)
- ESD (Electronic) At Least One Electronic ESD Station must be tested by simulation
monthly and documented, Verify all ESD’s stations are in working operation
• Semi-Annual (6 Months)
- SCSSV
- SSCSSV (Not In a Landing Nipple)
- Tubing Plugs
- TSH (Compressor)
- Injection Valves
• Annual (12 Months)

- TSH (Fired Component)
- SSCSSV (In a Landing Nipple)
- PSV
- BSL/TSL
- FSH, FSL
ESD Times
• Activation Times: 45 Seconds
• SSV – completed closure not to exceed 45 seconds after ESD has been activated.
All below safety device components, activation is not to exceed 45 seconds

• BSL
• SDV (All)
• BDV
• PSH
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• PSL
• PSL Lockouts (Pumps)
• Activation Times: Two (2) Minutes
• SCSSV - not exceed 2 minutes after the ESD is activated and the last SSV has closed
• How long records of inspections and test results should be kept?
All records of Subsurface and Surface Safety Devices testing and results shall be
maintained at the closet field office for a period of. Two (2) Years (All
Inspections)
All records shall show components tested, inspection dates, test results, any
adjustments, if replaced date replaced and retested.
Documents verifying certifications for SSV, SCSSV, SSCSV, and SSCSSV Landing
Nipples, and Locks kept indefinitely in well file at field office
Four (4)Years (Cranes) API 2D 4.2.2 Sixth Edition
Five (5) Years (Cranes) Deepwater API RP 2D, First Edition (Oct. 1972) Under USCG
Jurisdiction due to vessel designation.
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Subpart-O
(PSST)
Training
Module
8
Safety Analysis Checklists
Example Exercise,
SAC Reference Tables A.1 – A.10
With
Drawings & Schematics
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• SAFETY ANALYSIS TABLE (SAT)
What is a SAT Table?
It is a composite table that is applicable to regarding its Component position in the process flow
and safety devices required to counter act undesirable events.
The safety analysis of each process component highlighting undesirable events from which
protection should be provided along with detectable conditions which can be monitored
• SAFETY ANALYSIS CHECKLIST (SAC)

What is a SAT Table?
Table B-1 is a composite SAC for normally used process components. The SAC table lists the
safety devices required to protect each process component if it were viewed as an individual unit
with the worst probable input and output condition. Listed under each recommended device are
certain conditions that will eliminate the need for that particular device when the component is
viewed in relation to other components. The table justified what devices can be eliminated and
provides same protection with other safety devices that will not lead to a threat to safety.
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• SAFETY ANALYSIS CHECKLIST (SAC) Example Below:

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• SAFETY ANALYSIS FUNCTION EVALUATION CHART (SAFE Chart)

What is a SAFE CHART?
The Safe Chart is used to relate all sensing devices SDV’s, Shutdown devices and other
emergency support system to their functions.
The Safe Chart will list all their process components and ESS systems with their required
safety devices, list all functions to be performed by each device.
This will be shown on the Safe Chart. If the safety device is not needed (if it can be
omitted as determined in the SAC Reference List tables), the reason shall be listed in the
SAFE Chart format matrix by referring to the appropriate SAC Item number
Completion of the Safe Chart provides a means of verifying the design logic of the basic
safety system
The Safety Analysis Function Evaluation (SAFE) Chart (for a specific process facility) is
used to relate all safety sensing devices, SDVs (BDVs, etc.), Shutdown devices (including
ESD) and Emergency Support Systems to their functions (in a chart matrix format).
The SAFE chart will also list all process components and Emergency Support Systems with
their required safety devices and the function to be performed by each device.
The relationship of each with its required function must be documented (and verified) by
checking the appropriate “box” in the chart matrix.
Completion of the SAFE Chart provides the safety system designers, platform personnel
and BSEE inspectors with a means of verifying correct design logic of the facilities basic
safety system
Next Four (4) Pages is an example of a safe chart for the following page examples.
Examples of SAFE Charts are provided on the next four pages. Note that the Safe
Chart follows the typical progression of well stream contents flow from the Well
Head to the Departing Pipelines.
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Safety Analysis Checklist:

Flow line Segment Table A.1 - Diagramming Exercise.
A two Flow line segment, example schematic (for T2 & Subpart O class attendees) diagramming
exercise, is provided below. In order to begin the diagramming exercise, some basic information
concerning Well A14D must be provided. Assume the following parameters:
Well A14D - SITP: 2,560 PSI

Flow line Segment: FA 1 MAWP - 6,000 PSI.
Flow line Segment: FA 2 MAWP - 2,000 PSI.
From the Well information provided above, begin adding (diagramming the schematic above)
the safety devices required according to SAC Table A.1, Flow line Segments. Diagram or add the
symbol bubbles to the schematic provided by reading the safety device items listed in sections a
through d. Note that number 1 of each safety device item says or instructs to “install” the safety
device listed.
The second or proceeding numbers, provide a specific or justified (logical) reason for the safety
device’s omission from installation.
Using the following API RP 14C (SAC) Safety Analysis Checklist you can find and install on a safe
chart the required safety devices.
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API RP 14C
Table B-1—Composite
Safety Analysis Checklist (SAC)
Table A.1 Flow Line Segment
a. High Pressure Sensor (PSH)

1. PSH installed.
2. Flow line segment has a Maximum Allowable Working Pressure greater than maximum
shut in pressure and is protected by a PSH on a downstream flow line segment.
b. Low Pressure Sensor (PSL)
1. PSL installed
2. Flow line segment is between the well and the first choking device and is less than 10
feet (3m) in length or, in the case of an underwater installation, reasonably close to
that distance.
c. Pressure Safety Valve (PSV)
1. PSV installed.
2. Flow line segment has a Maximum Allowable Working Pressure greater than the
maximum shut in pressure
3. Two SDVs (one of which may be the SSV) with independent PSHs, relays, and sensing
points are installed where there is adequate flow line volume upstream of any block
valves to allow sufficient time for the SDVs to close before exceeding the Maximum
Allowable Working Pressure.
4. Flow line segment is protected by a PSV on upstream segment
5. Flow line segment is protected by a PSV on downstream component that cannot be
isolated from the flow-line segment and there are no chokes or other restrictions
between the flow line segment and the PSV
d. Flow safety Valve (FSV)
1. FSV installed
2. Flow line segment is protected by FSV in final flow line segment.
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Table A.1 Flow line Segment
Five different Flow line Segment schematics from API RP 14C and a simplified, two Flow line
segment, illustration are provided to show the safety devices required
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.
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Table A.2 Wellhead Injection Lines:
An illustration of a typical Wellhead Injection Line is provided next to show the safety devices
required.
A.2 Wellhead Injection Lines

1. PSH installed
2. Line and equipment are protected by an upstream PSH
1. PSL installed
2. Line and equipment are protected by an upstream PSL
1. PSV installed
2. Line and equipment have a Maximum Allowable Working Pressure greater than the
maximum pressure that can be imposed in the injection source.
3. Line and equipment are protected by an upstream PSV
d. Check Valve (FSV)
1. FSV(s) installed.
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Table A.3 Headers

1. PSH installed
2. Each input source is equipped with a PSH set less than the Maximum Allowable
Working Pressure of the header.
3. Header is protected by downstream PSH that cannot be isolated from the header.
4. Header is for flare, relief, vent, or other atmospheric service and has no valving in the
outlet piping.
1. PSL installed
2. Each input source is protected by a PSL and there are no pressure control devices or
restrictions between the PSL and the header.
3. Header is for flare, relief, vent, or other atmospheric service
1. PSV installed
2. Header has a Maximum Allowable Working Pressure greater than the maximum shut in
pressure of any connected well.
3. Pressure relief protection is provided on each input source having a maximum shut in
pressure greater than the Maximum Allowable Working Pressure of the header.
4. Header is protected by downstream PSV that cannot be isolated from the header.
5. Header is for flare, relief, vent, or other atmospheric service and has no valving in the
outlet piping.
6. Input source is a well(s) having a pressure greater than the Maximum Allowable
Working Pressure of the header and is equipped with two SDVs (one of which may be
the SSV) controlled by independent PSHs connected to separate relays and sensing
points. Other input sources having a pressure greater than the Maximum Allowable
Working Pressure of the header are protected by PSVs.
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Table A.3 Header
A typical Header schematic from API RP 14C and a simplified illustration is used to show the
safety devices required on Header Manifolds are depicted next.
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Table A.4 Pressure Vessels

1. PSH installed
2. Input is from a pump or compressor that cannot develop pressure greater than the
Maximum Allowable Working Pressure of the vessel.
3. Input source is not a wellhead flow line(s), production header, or pipeline and each
input source is protected by a PSH that protects the vessel.
4. Adequately sized piping without block or regulating valves connects gas outlet to
downstream equipment protected by a PSH that also protects the upstream vessel.
5. A vessel is final scrubber in a flare, relief, or vents system and is designed to withstand
maximum built up back pressure.
6. Vessel operates at atmospheric pressure and has an adequate vent system
1. PSL installed
2. Minimum operating pressure is atmospheric pressure when in service
3. Each input source is protected by a PSL and there are no pressure control devices or
restrictions between the PSL(s) and the vessel
4. Vessel is scrubber or small trap, is not a process component, and adequate protection
is provided by downstream PSL or design function (e.g., vessel is gas scrubber for
pneumatic safety systems or final scrubber for flare, relief, or vent system).
5. Adequately sized piping, without block or regulating valves connects to gas outlet to
downstream equipment protected by a PSL that also protects the upstream vessel.
1. PSV installed
2. Each input source is protected by a PSV set no higher than the Maximum Allowable
Working Pressure of the vessel and a PSV is installed on the vessel for fire exposure
and thermal expansion.
3. Each input source is protected by a PSV set no higher than the vessel’s, at least one of
these PSVs cannot be isolated from the vessel
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4. PSVs on downstream equipment can satisfy relief requirement of the vessel and
cannot be isolated from the vessel.
5. Vessel is final scrubber in a flare, relief, or vent system, is designed to withstand
maximum built up back pressure, and has no internal or external obstructions, such as
mist extractors or back pressure valves.
6. Vessel is final scrubber in a flare, relief, or vent system, is designed to withstand
maximum built up back pressure, and is equipped with a rupture disk or safety head
(PSE) to bypass any internal or external obstructions, such as mist extractor or back
pressure valves.
d. High Level Sensor (LSH)
1. LSH installed
2. Equipment downstream of gas outlet is not a flare or vent system and can safely
handle maximum liquid carry-over.
3. Vessel function does not require handling separated fluid phases.
4. Vessel is small trap from which liquids are manually drained.
e. Low Level Sensor (LSL)
1. LSL installed to protect each liquid outlet
2. Liquid level is not automatically maintained in the vessel and the vessel does not have
an immersed heating element subject to excess temperature.
3. A control device in the line will effectively minimize backflow.
f. Check Valve (FSV)
1. FSV installed on each outlet
2. The maximum volume of hydrocarbons that could backflow from downstream
equipment is insignificant.
3. A control device in the line will effectively minimize backflow.
g. High Temperature Sensor (TSH)
1. TSH installed
2. (Deleted in Second Edition)
3. Heat source is incapable of causing excess temperature.
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Table A.4
A simplified illustration of a three-phase Process Separator and a Pressure Vessel schematic
from API RP 14C are both provided to show the safety devices required by Table A.4.
Note that the Pressure Vessel schematic provided (second drawing) depicts a typical vertical,
two-phase Pressure Vessel (Separator).
Two Phase Separator Below

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Table A.4 Pressure Vessels
Three Phase Separator

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Table A. 5 Atmospheric Vessels
a. Vent
1. Vent installed.
b. Pressure, Vacuum Relief Device (PSV)
1. PSV installed
2. Vessel has second vent capable of handling maximum gas volume
3. Component is a pressure vessel, not subject to collapse, that operates in atmospheric
service and is equipped with an adequately sized vent.
4. Vessel has no pressure sources (except blanket gas and/or manual drains) and is
equipped with an adequately sized vent
c. High Level Sensor (LSH)
1. LSH installed
2. Fill operations are continuously attached
3. Overflow is diverted or contained by other process components.
d. Low Level Sensor (LSL)
1. LSL installed
2. Adequate containment system is provided
3. Liquid level is not automatically maintained in the vessel and vessel does not have an
immersed heating element subject to excess temperature.
4. Component is final vessel in a containment system designed to collect and direct
hydrocarbon liquids to a safe location.
e. High Temperature Sensor (TSH)
4. TSH installed
5. (Deleted in Second Edition)
6. Heat source is incapable of causing excess temperature.
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Table A.5
An Atmospheric Pressure operated Skimmer vessel illustration and an Atmospheric Vessel
(Tank) schematic from API RP 14C are both used to show the safety devices required by Table
A.5.
Note: The Oil Level Controller is omitted on Skimmer type vessel for clarity.
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Table A.6 Fired and Exhaust Heated Components
a. High Temperature Sensor (medium or process fluid) (TSH)

1. TSH Installed
2. Component is a steam generator protected by a PSH and, if fired, by a LSL
3. Component is an indirect water bath heater in atmospheric service and is protected by
an LSL
b. High Temperature Sensor (stack) (TSH)
1. TSH installed
2. Component is isolated and does not handle combustible medium or process fluids
other than fuel.
3. Component is exhaust heated without supplemental firing and medium is not
combustible
c. (Deleted in Second Edition)
d. Low Pressure Sensor (air supply) (PSL)
1. PSL installed
2. Component is equipped with natural draft burner
3. Forced draft burner is equipped with another type of low air supply sensor
4. Component is exhaust heated without supplemental firing
e. High Pressure Sensor (fuel supply) (PSH)
1. PSH installed
f. Low Pressure Sensor (PSL)
1. PSL installed
2. Component is equipped with a natural draft burner.
g. Flame Failure Sensor (BSL)
1. BSL installed
h. Low Flow Sensor (heated medium) (FSL)
1. FSL installed
2. Component is not a closed heat transfer type in which a combustible medium flows
through tubes located in the firing or exhaust heated chamber
i. Motor Interlock (forced draft fan motor).
1. Motor interlock installed
2. Component is equipped with a natural draft burner
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j. Flame Arrestor (Air Intake)

1. Flame arrestor installed
2. Component is equipped with a forced draft burner
3. Component is located in an isolated area and not handling combustible medium or
process fluids other than fuel
k. Stack Arrestor
1. Stack arrestor installed
2. Component is equipped with a forced draft burner and (1) the fluid being heated is
non-flammable, or (2) the burner draft pressure at the exit of the transfer section is
higher than the fluid pressure (head)
3. Component is isolated so process fluids will not contact stack emissions
l. Pressure Safety Valve (medium circulating tube) (FSV)
1. PSV installed
2. Component is not a tube type heater
3. PSV installed on another component will provide necessary protection and the PSV
cannot be isolated from the tube section
m. Check Valve (medium circulating tube) (FSV)
1. FSV installed on each outlet
2. The maximum volume of combustible media that could backflow from downstream
equipment is insignificant, or medium is not combustible
3. Component is not a tube type heater.
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Table A.6
For Fired Vessel & Exhaust Heated Components.
A Glycol Reboiler & Heater Treater schematic example from API RP 14C is provided on the next
page to depict the
typical safety
devices required
by Table A.6.
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Table A.6 Fired and Exhaust Heated Components
Important Note: Please note in reality, the LSL depicted in the previous schematics, should
actually be positioned above the Fire tube assemblies.
Note that the example drawing provided next shows the LSHL assembly correctly positioned
above the Fire tube, which in turn protects the fire tube from being uncovered within the Glycol
Reboiler vessel.
Remember that the fluid media LSL located within the fired side of the vessel must always be
positioned above the Fire tube assembly.
A simplified, cross-sectional Glycol Reboiler (Fired Vessel) illustration is provided next.

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Table A.7 Pumps
a. High Pressure Sensor (PSH)—pipeline pumps

1. PSH installed
b. High Pressure Sensor (PSH)—other pumps
1. PSH installed
2. Maximum pump discharge pressure does not exceed 70 percent of the Maximum
Allowable Working Pressure of discharge piping
3. Pump is manually operated and continuously attended
4. Small, low volume pumps, e.g., chemical injection pumps
5. Pump discharges to an atmospheric vessel
6. Pump is a glycol powered glycol pump
c. Low Pressure Sensor (PSL)—pipeline pumps
1. PSL installed
2. Pump does not handle hydrocarbons
d. Low Pressure Sensor (PSL)—other pumps
1. PSL installed
2. Pump is manually operated and continuously attended
3. Adequate containment is provided
4. Small, low volume pumps, e.g. chemical injection pumps
5. Pump discharges to an atmospheric vessel
e. Pressure Safety Valves (PSV)—pipeline pumps
1. PSV installed
2. Pump is kinetic energy type and incapable of generating a head greater than the
Maximum Allowable Working Pressure of the discharge piping
f. Pressure Safety Valves (PSV)—other pumps
1. PSV installed
2. Maximum pump discharge pressure is less than the Maximum Allowable Working
Pressure of discharge piping.
3. Pump has internal pressure relief capability
4. Pump is glycol powered glycol pump and the wet glycol low pressure discharge piping
is rated higher than the maximum discharge pressure
5. Pump is a glycol powered glycol pump, and the wet glycol low pressure discharge
piping is protected by a PSV on a downstream component that cannot be isolated
from the pump.
g. Check Valve (FSV)—all pumps
1. Check valve installed.
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Table A.7 Pumps.
A Pump example schematic from API RP 14C and a pneumatic pressure operated, diaphragm
Pump assembly drawing, are provided next to depict the typical safety devices required.
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Table A.8 Compressors
a. High Pressure Sensor (PSH) -- Suction

1. PSH installed
2. Each input source is protected by a PSH that will also protect the compressor
b. High Pressure Sensor (PSH)--Discharge
1. PSH installed
2. Compressor is protected by a downstream PSH, located upstream of any cooler, that
cannot be isolated from the compressor
c. Low Pressure Sensor (PSL)--Suction
1. PSL installed
2. Each input source is protected by a PSL that will also protect the compressor
d. Low Pressure Sensor (PSL)--Discharge
1. PSL installed
2. Compressor is protected by a downstream PSL that cannot be isolated from the
compressor
e. Pressure Safety Valve (PSV) — Suction
1. PSV installed
2. Each input source is protected by a PSV that will also protect the compressor
f. Pressure Safety Valve (PSV) -- Discharge
1. PSV installed
2. Compressor is protected by a downstream PSV, located upstream of any cooler, that
cannot be isolated from the compressor
3. Compressor is kinetic energy type and incapable of generating a pressure greater than
the Maximum Allowable Working Pressure of the compressor or discharge piping.
g. Check Valve (FSV) — Final Discharge
1. FSV installed
h. High Temperature Sensor (TSH)
1. TSH installed
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Table A.8 Compressors
A Compressor example schematic from API RP 14C and a simplified assembly drawing are
provided next to depict the typical safety devices required. Note: The BDV is typically installed
or located on the “Final Discharge” side or outlet connection of a
Compressor’s piping.
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Table A.9 Pipelines

1. PSH installed
2. Delivering pipeline protected by PSH located on upstream component
3. Each input source is protected by a PSH that also protects a departing or bi-directional
pipeline
1. PSL installed
2. Delivering pipeline protected by PSL located on upstream component
3. Each input source is protected by a PSL that also protects a departing or bi-directional
pipline
4. The pipeline is protected by a PSL located on a parallel component
1. PSV installed
2. Pipeline has a maximum allowable operating pressure greater than the maximum
pressure of any input source.
3. Each input source having a pressure greater than the maximum allowable operating
pressure of the pipeline is protected by a PSV set no higher than the maximum
allowable operating pressure of the pipeline.
4. The pipeline does not receive input from the platform process
5. Input source is a well(s) having a pressure greater than the maximum allowable
operating pressure of the pipeline and is equipped with two SDVs (one of which may
be the SSV) controlled by independent PSHs connected to separate relays and sensing
points. Other input sources having a pressure greater than the maximum allowable
operating pressure of the pipeline are protected by PSV
d. Check Valve (FSV)
1. FSV installed
2. Departing pipeline is equipped with an SDV controlled by a PSL
3. Each input source is protected by an FSV located so that no significant length of
pipeline is unprotected from backflow
4. Pipeline is used for bi-directional flow.
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Table A.9 Pipelines.
Simplified assembly drawings of an Incoming, Departing and Bidirectional pipelines are provided
next to depict the typical safety devices required.
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A.10 Heat Exchangers

1. PSH installed
2. Input source to heat exchanger section cannot develop pressure greater than the
Maximum Allowable Working Pressure of the heat exchanger section.
3. Each input source is protected by a PSH that also protects the heat exchanger section
4. A PSH is installed on a downstream component and cannot be isolated from the heat
exchanger section by block or regulating valves.
1. PSL installed
2. Minimum operating pressure is atmospheric pressure when in service
3. PSL installed on another component will provide necessary protection and the PSL
cannot be isolated from the heat exchanger section when the heat exchanger is in
service.
1. PSV installed
Working Pressure of the heat exchanger section and a PSV is installed on the heat
exchanger section for fire exposure and thermal relief.
3. Each input source is protected by a PSV that is set no higher than the Maximum
Allowable Working Pressure of the heat exchanger section and that cannot be isolated
from the heat exchanger section.
4. PSVs on downstream equipment can satisfy relief requirement of the heat exchanger
section and cannot be isolated from the heat exchanger section.
5. (Deleted in Fourth Edition).
6. Input sources to the heat exchanger section cannot develop pressure greater than the
Maximum Allowable Working Pressure of the heat exchanger section and the heat
exchanger section cannot be over-pressured due to temperature or pressure in the
other section
Working Pressure on the heat exchanger section and the heat exchanger section
cannot be over-pressured due to temperature or pressure in the other section.
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Table A.10 Heat Exchanger
A simplified assembly drawing of a tube–in-shell type Heat Exchanger is provided next to depict
the typical safety devices required.
Summary
All of the safety devices to be typically installed on Flowline Segment FA1 will be justifiably
omitted from installation. Each item’s omission is justified since the MAWP of FA1 (6,000 PSI) is
greater the SITP (2,550 PSI). Please note that Flowline Segment FA1 is shorter than 10 feet in
length (shown as <10’). Therefore, the PSL is not required to be installed.
All of the safety devices omitted from installation on Flowline Segment FA1 will be denoted by
the dashed (dotted) circle. As stated previously, (within the safety device symbol or bubbles
presentation and depiction) “serves to represent the device proper,” or in other words, its
omission is justified as defined within Safety Analysis Checklist Table A.1. The justification for
omission must be noted (listed) in the Safety Analysis Function Evaluation (SAFE) chart under the
Alternate Protection heading or columns. Under the SAC Ref. Number column would be listed:
A.1a2. Next would be inserted in the safety device under the Alternate Device listing would be:
PSH (within the first column). The second column would be left blank. The third column requires
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the insert of the location of the Alternate Protective device: FA2. The fourth column requires
the identification of the corresponding Well Number or Vessel number: shown as A14D.
Flowline Segment FA2 requires that all safety devices be installed since MAWP of FA2 (2,000 PSI)
is less than the SITP (2,550 PSI). Therefore, the four symbol bubbles or balloons for PSH, PSL (or
PSHL), PSV and FSV must all appear or be drawn on Flowline Segment FA2.
Conclusion
From each Wellhead to the Departing Pipelines, all process vessels, components, associated
equipment and systems must have a relevant flow schematic and be listed on the SAFE Chart.
Completion of the SAFE Chart provides the safety system designers, platform personnel and
BSEE inspectors with a means of verifying correct design logic of the facilities basic safety
system.
The descriptions for SAC, SAFE and SAT provided previously within the Important Abbreviation &
Description section of Module One should be reviewed.
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Subpart-O
(PSST)
Training
Module
9
Identification Exercise
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The objective of this module is to provide attendees with a visual understanding of basic safety
devices utilized on production facilities.
This module will allow an entry-level employee to recognize Safety Sensors & Safety Devices
typically used on production components
ASH – Analyzer Safety High Gas Detector
BDV - Blow Down Valve

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CRBBM - Control Relay Block & Bleed Manual
30 PSI
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ESD - Emergency Shut Down
FSV - Flow Safety Valve

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Norriseal – LSHL:
LSH LSL
Fisher 2100 – LSHL

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PSHL (Pressure Sensors Field & Panel Mount Assemblies)
PSHL - Pressure Safety High & Pressure Safety Low
PSV - Pressure Safety Valve

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SDV – Shut Down Valve
Fisher Type & Robot Arm Actuator
SSV - Surface Safety Valve

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SCSSV - Surface Control Sub Surface Safety Valve
SSCSV - Sub Surface Control Sub Surface Safety Valve
SCSSV SSCSV (Storm Choke)
TSE - Temperature Safety Element

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TSH – Temperature Safety High
Ex-Line, Kimray T-12: Temperature Controller & Thermowell
Ex-Line Kimray
Fired Vessels) BSL: Flame Arrestor, Stack Arrestor, Burner Safety Low
Flame Arrestor
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Atmospheric Vessel – Stock Tank:

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Subpart O
(PSST)
Training
Module
10
Safety System Component Identification
Balloon Symbol Exercise
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Add the appropriate Safety Device Abbreviation in the balloon bubbles shown.
01. ____
02. ____
03. ____
04. ____
05. ____
06. ____
07. ____
08. ____
09. ____
10. ____
11. ____
12. ____
13. ____
14. ____
15. ____
16. ____
17. ____
18. ____
19. ____
20. ____
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Subpart O
(PSST)
Training
Module
11
BSEE - USCG Requirements
USCG 33 CFR 140 Thru 147
BSEE Z Pincs Z-100 Thru Z-210

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There is a letter of memorandum of understanding dated November 27, 2012

between USCG and BSEE authorizing BSEE to conduct inspection and enforce
USCG regulations on OCS facilities.
Approved
Means approved by the USCG Commandant, unless otherwise specified.
Attending Vessel
Means a vessel which is moored close to and readily accessible from an OCS facility for the
purpose of providing power, fuel or other services to the operation being conducted on the
facility. If safety equipment is stored on attending vessel, must be moored to platform or close-
by. Attending vessel cannot leave platform area with safety equipment on board.
Commandant
Means Commandant of the Coast Guard or that person’s authorized representative.
Emergency Evacuation Plan (EEP)

Every Manned Facility shall maintain an “approved” EEP onboard or closest field office. EEP’s are
to be submitted to commandant OCMI for approval. The plan must also be approved by BSEE or
USCG. The EEP's shall contain information required by 33 CFR 146.
A BSEE/USCG approval letter must be filed along with EEP Plan.
Emergency Evacuation Plan must be kept up to date as drilling, construction, owner, operator,
helicopter company, boat company changes occur and should have an approval letter from both
the USCG & BSEE.
Emergency Evacuation Plan Drills:

At least once a year, all elements of the EEP relating to the evacuation of personnel from the
facility must be exercised through a drill or series of drills. At least once a month, an emergency
drill must be conducted that demonstrates the ability of both crews to perform their duties as
described in the EEP. The date and time of such drills shall be reported to the owner of the
facility and shall be maintained for two years. This applies to on site vessels and manned
platforms only
EEP Drills SEMS Rules Section API RP 75 10.4 Training and Drills
Training incorporating emergency response and evacuation procedures should be conducted
~
periodically (Monthly) for all personnel (including contractor's personnel), as required by the
lessee management program. Drills based on realistic scenarios should also be conducted
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periodically (Monthly) to exercise all elements contained in the facility or area emergency action
plan. An analysis and critique of each drill should be conducted to identify and correct
Any weaknesses or stengths notes as appropriate. This critique analysis should be noted on the
monthly drill report when drill is completed
Manned Facility/Manned Platform:

Means an OCS facility on which people routinely work on or are accommodated for more than
twelve (12) hours in successive twenty-four (24) hour periods.
Unmanned Facility/Unmanned Platform:

Fixed OCS facility that is not a manned facility and persons not sleeping on facility , even though
an attending vessel may continually service it.
OCMI (Officer in Charge, Marine Inspection):

Person who commands a Marine Inspection Zone and who is immediately responsible for the
performance of duties with respect to the inspections, enforcement, and administration of
regulations governing units.
Persons in Charge (PIC):

The master or other individual designated as such by the owner or operator by letter.
Self-Inspection Report CG-5432: 33 CFR 140.103

A copy of the self-inspection report shall be maintained on the platform. If the platform is not
manned, the report can be maintained at an adjacent platform or in the operator’s office if
operator has no manned platforms in the area.
Keep copy in field of form CG-5432 for 2 years.
If there are any discrepancies when conducting inspection, Correct All discrepancies must be
corrected as soon as Practical 33 CFR 140.105, then fill out the 5432 report
Note: The USCG 5432 report MUST be signed by the inspector, (Not Typed)
There is also a requirement to conduct an annual inspection of all firefighting and lifesaving
equipment, document annual inspection. Should match 5432 Report 33 CFR 140.103
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USCG CG-5432 Self Inspection Report 33 CFR 140.103

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Station Bill
1. Contains specific duties and duty stations for platform personnel in case of an
emergency.
2. It contains specific signals for emergency stations and for the abandonment of the
facility.
3. It shall list the use and application of any special equipment to be provided in an
emergency.
4. The Station Bill must be signed by PIC designated by letter by owner or operating
company (not foreman on different Platform) and posted in conspicuous places on the
facility.
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Emergency Signals
The signal to man emergency stations shall be an intermittent signal on the general alarm
systems for not less than ten seconds. The abandon facility shall be a continuous signal on the
general alarm system (this applies to manned platforms only). There should be General Alarm
signs affixed adjacent each alarm speaker with 1 Inch white background Red Letters
General Alarm System:
1. Each manned facility must have a general alarm system.
2. When operated, this system shall be audible in all parts of the structure on which
provided.
3. The general alarm bell switches shall be identified by red letters at least one (1) inch high
with a contrasting background: “General Alarm”.
4. All general alarm bells shall be identified at each bell in red letters at least one (1) inch
high with sharp contrasting background: “General Alarm – When Bell Rings Go to Your
Station”.
Insure alarms (fire, abandon) can be heard in different areas of the platform, inside and out. The
drilling rig alarms do not have to be tied in-to production platform alarms (it is a good practice,
but not a law)
Emergency Drills 33 CFR 146.115 33 CFR 146.120

Drills are to be conducted monthly and as if an actual emergency exist.
a. PIC shall instruct all personnel that they should report to their respective stations, be
prepared to perform their assigned duties.
b. PIC shall instruct the personnel as necessary to insure all personnel are familiar with their
duties. (Consult Facility EEP for drill content).
c. PIC shall assign a person to each life float, lifeboat, life raft, or survival capsule who shall
be responsible for launching it in event of an emergency
Waste Management Plan/Garbage Log

Each facility’s waste management plan must be in writing, kept on board the platform and
describe procedures for collecting, processing, storing, and discharging garbage. The Waste
Management Plan must also designate the person in charge of carrying out the plan. If no plan
is onboard the facility, the platform can be shut-in (according to 33 CFR 151.55-77). A monthly
garbage log identifying the Date transfer, Facility ID, Amount of garbage, Vessel Name, Vessel ID
Number is required to be kept on file for two years
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The law was written and passed in 1990-1991 for garbage transfer from the facility to a vessel
which must include name of vessel & Chain of Custody documentation. The old name for the
procedure was MARPO. Once it’s on the boat, It’s the vessel responsibility for upkeep till
offloaded at dock
Food Disposal Marpol Annex V

• from 0-12 miles offshore - zero (0) or no food discharge,
• 12-24 miles offshore - grind food, (no paper or plastics),
• Over 25 miles offshore – disposal overboard of food is ok, (no paper or plastics).
• This law has not been enforced in past, but it has changed.
Open Container Burning
No open container burning is allowed on or from platforms.
Fire Equipment Servicing Reports

Third party Inspection Reports should be on board and account for all equipment. Platform
personnel may perform inspections if National Fire Protection Association (NFPA) or equivalent
specifications are followed.
Notes: Annual inspections can be done by company employees. It must document all work and
inspections. CO2 must be weighed. Fire Extinguisher reports do not require serial numbers.
Hydro is done every 12 years by an outside firm. Wheel units and new agents are done every 6
years.
Lifesaving Appliances Servicing Report

Third Party Inspection Reports should be on board and account for all equipment, life rafts,
boats, etc.
Personal Protection Equipment: 33 CFR 140.7

Each facility shall be “maintained in compliance with workplace safety and health regulations of
this part and in addition, free from recognized hazards.” Each leaseholder and persons
responsible for the actual operations shall ensure all personnel use and wear the proper
personal protective equipment.
The prime areas of concern for workplace safety (which should be addressed) are:
1. Personal protective clothing/equipment to include eye, head and foot protection

2. General cleanliness
3. Tripping hazards/oil on deck
4. Safety belts and lifelines
5. Eyewash equipment
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• Eye/Face Protection: Personnel engaged in or observing welding, grinding, chipping,
handling hazardous materials, chemical handling or acetylene burning or cutting, shall
wear eye and face protection that is marked in accordance with ANSI Z87.1-1979 33 CFR
142.27
• Eyewash Equipment: Portable of fixed eyewash equipment must be readily available

near mudrooms, drill floor and any other area where there is a possibility of eye injury.
• Verify that the eyewash has not expired and flush the shower head and eyewash at least
once a day to help remove contaminates.
Note: Rule of thumb No obstacles in the way, 10 seconds max walking to station 50Ft.
• Head Protection: Head protection that is marked in accordance with ANSI Z89.1-1981 33
CFR 142.30 shall be worn by personnel in areas where there is a hazard of falling objects
or contact with electrical conductors. Follow manufactures recommended requirements
• Foot Protection: Foot protection that is marked in accordance with ANSI Z41-1983 33
CFR 14.33 shall be worn by personnel working in areas or engaged in activities where
there is a reasonable probability of foot injury may occur.
• Respiratory Protection: Personnel in an atmosphere specified in ANSI Z88.2-1980 33

CFR 142.39 shall wear the equipment specified in Z88.2. Personnel shall be trained and
follow proper appropriate procedures. Respiratory protection equipment must be
approved, used and maintained IAW ANSI Z88.2.
• Safety Belts and Lifelines: Except when moving from one location to another.
Remember if at height 100% tie off is required.
• Any personnel that are engaged in an activity where there is a hazard of falling (Lessee)
six (6) feet or more feet (BSEE) 10 Feet (OSHA) 4 Feet shall wear a safety belt or body
harness that meets the specifications outlined in ANSI A10.14-1975 33 CFR 142.42
• Note: Follow Lessee or contractor plan whichever is more strenuous
• Safety belts and harnesses shall be secured by a lanyard to a drop line, lifeline or fixed
anchorage that is capable of handling 5000# shock loads. Always use the most strenuous
safety harness requirement
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Lock Out Tag Out 33 CFR 142.90
(a) While repair or other work is being performed on equipment powered by an external
source, that equipment must be locked out as required in paragraph (b) of this section or, if
a lockout provision does not exist on the equipment, must be disconnected from the power
source or otherwise deactivated, unless the nature of the work being performed
necessitates that the power be connected or the equipment activated.
(b) If the equipment has a lockout or other device designed to prevent unintentional
activation of the equipment, the lockout or other device must be engaged while the work is
being performed on the equipment, unless the nature of the work being performed
necessitates that the equipment be activated.
(c) A tag must be placed at the point where the equipment connects to a power source and
at the location of the control panel activating the power, warning—
(1) That equipment is being worked on; and
(2) If the power source is disconnected or the equipment deactivated, that the power source
must not be connected or the equipment activated.
(d) The tags must not be removed without the permission of either the person who placed
the tags, that person’s immediate supervisor, or their respective reliefs.
Navigation Equipment (Lights & Warning Devices)

Obstruction Lights:
a. Obstruction lights must have 360-degree lenses, display a quick-flash characteristic of
approximately sixty (60) flashes per minute, should be visible for at least five (5) miles and
be displayed at not less than twenty (20) feet above the water.
b. When more than one light is displayed, all lights must flash in unison.
c. Obstruction lights on Class “A” structures shall be white.
d. Lights are to be displayed at all times between the hours of sunset and sunrise and during
periods of reduced visibility.
Structures having a horizontal dimension of thirty (30) feet or less are required to have one (1)
obstruction light with 360-degree visibility. Structures having a horizontal dimension between
thirty (30) and fifty (50) feet are required to display two (2) obstruction lights on diagonal
corners. Structures over fifty (50) feet are required to display one obstruction light on each
corner.
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Fog Signal Device:

Fog signaling devices are required on all structures.
a. The horn is required to sound a two (2) second blast every twenty (20) seconds, be audible
for a two (2) mile range, operate when visibility drops below three (3) miles, and be USCG
approved.
b. Verify USCG Certification Tag on is attached on Horn
c. Satellites close together can get waiver for fog horn overlap.
Means of Escape: 33 CFR 143.101

A primary means of escape is defined as a fixed stairway or vertical ladder of metal construction.
Ladders greater than 20 feet must have fall protection cages.
Secondary means of escape can be additional type approved for primary means of escape or a
portable flexible ladder, knotted manropes or other devices satisfactory to the OCMI.
Manned OCS Facilities: Manned OCS facilities shall be provided with at least two (2)
primary means of escape extending from the uppermost platform level that contains living
quarters or that personnel occupy continuously, to each successively lower working level and to
the water surface. 33 CFR 143.101
• Working levels without living quarters, workshops or offices or other spaces that personnel
do not continually occupy, require one primary means of escape and one or more secondary
means of escape determined by the OCMI. 33CFR 143.101(c)
Unmanned OCS Facilities: Unmanned OCS facilities require one primary means of escape and
either 33 CFR 143.101(d)
a. One additional primary means of escape or

b. A secondary means of escape for every ten (10) persons onboard at any one time.
(Escape Rope is sufficient)
Guards and Rails 33 CFR 143.110
The unprotected perimeter of catwalks, deck areas, and openings must be protected with rails,
steel cable, or wire mesh at least forty-two (42) inches high. If cable used at +10 level in lieu of
handrail pipe, must be tight, chain is not accepable.
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The Unprotected Perimeter of All Catwalks, Deck Areas, and Openings: 33 CFR 143.110
If guardrails are used they must have three courses of rail with the two (2) intermediate courses
evenly spaced between the deck and the top course. Or if a toe board is used the bottom course
may be omitted and the remaining course place between the toe board and top course.
Stairways 33 CFR 143.110
Stairways require two courses of rail with the top course at least thirty-four (34) inches above
the tread.
Helicopter Landing Deck: 33 CFR 143.11 API RP 2L

The unprotected perimeter of the helicopter landing deck shall be provided with a device with
sufficient strength and size to prevent any person (200 lbs) from falling through.
Helicopter skirting may be corrugated tin or chain link but it must be maintained.
Heliport lighting on manned facilities is required and in operation only at night, (Unmanned
facilities heliport lighting is optional). Blue lights on heliport corners with red lights on sides.
Lifesaving Equipment:
Manned Platforms: 33 CFR 144.01
LIFE FLOATS are the minimum primary lifesaving equipment required on platforms. There
must be a minimum of two (2) approved life floats on board and additional as required of
sufficient capacity to accommodate 100% of the persons on board the platform. And in a
manner be readily launched
Life Float Requirements:

1. The life floats shall be distributed in accessible locations and mounted on the
outboard sides of the working platform so they can be readily launched.
2. Each life float shall be provided with a painter. Painter length shall be three (3) times
from the deck level to the water level
3. Each life float shall have a buoy light attached with painter length of 6-12 Feet in
length, Buoy light to be mounted on the outside of the handrail.
4. Each life preserver shall be marked with the name or number of the facility. Life
preservers, which accompany mobile crews to unmanned platforms, may be marked
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with operator’s name and field designation. Donning instructions should be posted in
a conspicuous place and should reflect the type of the life jackets onboard. While
working over water, a work vest is required
INFLATABLE life rafts may be substituted for life floats. These have to be recertified
annually as per SOLAS Requirements
SURVIVAL CRAFT (Capsules or Boats) may also be substituted for the required life floats.
LIFE PRESERVERS 33 CFR 144.01-20 an approved type 1 life preserver shall be provided for
each person on a manned platform. The life preservers shall be located in easily accessible
places. Each life preserver shall have personal flotation device attached to the front shoulder
area, 200 Sq. Cm reflective material front and back and PML attached
RING LIFE BUOYS – Each platform must have at least four approved life buoys placed in a
suitable rack on each side of the platform. The life buoys must always be capable of being
cast loose and may not be permanently secured in any way.
1. Each ring buoy shall have an approved automatic water light attached with a three
(3) to six (6) foot long, twelve (12) thread manila or equivalent synthetic lanyard.
2. Water light must be mounted in a bracket and capable of being pulled free when
buoy is cast loose. (Attached to the outside of the handrail)
3. Each ring buoy shall be marked with name or number of the facility.
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FIRST AID KIT – A first aid kit approved by the USCG of US Bureau of Mines (inventory listing)
shall be provided onboard.
LITTER – A Stokes litter or other suitable litter capable of being safely hoisted with an
injured person shall be kept in an accessible location. (Aviation Straps)
EMERGENCY COMMUNICATION EQUIPMENT – A means of communication by radio and/or

wire telephone must be provided for contacting the shore base or vessels in the vicinity.
Unmanned Platforms
No person or persons may be on an unmanned platform unless the following equipment is

readily accessible:
• LIFE PRESERVER – An approved life preserver shall be provided for each person onboard.
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• RING LIFE BUOY – An approved ring life buoy must be provided for every two (2) persons
onboard but no more than four (4) are required. Buoys may be kept on attending vessel
that remains alongside the platform if there is no available space on the platform. Life
preserver boxes should be on lower level of platform since it is more accessible. If type 1
PFDs is not available for personnel, personnel must be removed. PFD reflective tape can
be repaired in field. Donning Placard must match PFD shown.
Life Float Requirements:

1. The life floats shall be distributed in accessible locations and mounted on the outboard
sides of the working platform so they can be readily launched.
2. Each life float shall be provided with a painter 6 (six) to 12 (twelve) Feet Long
3. Each life preserver shall be marked with the name or number of the facility. Life
preservers, which accompany mobile crews to unmanned platforms, may be marked with
operator’s name and field designation. Donning instructions should be posted in a
conspicuous place and should reflect the type of the life jackets onboard. While working
over water, a work vest is required.
Ring Life Buoys:

1. Each ring buoy shall have an approved automatic water light attached with a three (3) to
six (6) foot long, twelve (12) thread manila or equivalent synthetic lanyard.
2. Water light must be mounted in a bracket and capable of being pulled free when buoy is
cast loose.
3. Each ring buoy shall be marked with name or number of the facility.
4. Ring buoys, which accompany mobile crews to unmanned platforms, may be marked with
the operator’s name and field designation. Life rings are to mount the light holder on the
outside of the handrail for easy release.
Classification of Fire Extinguishers:

Portable and semi-portable Fire Extinguishers are classified by a combination letter and number
symbol. The letter indicates the type of fire the unit could be expected to extinguish and the
number denoting the size.
Type indicators are as follows:
• “A” Alpha Fires involving ordinary combustible materials

• “B” Bravo Flammable liquid fires
• “C” Charlie Electrical fires
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• “D” Delta Metal fires
• “K” Kilo Kitchen fires
Note: Fire Extinguishers should not be placed resting on grating. Fire Extinguishers are be
placed at least four inches off the floor. BSEE will give leeway on brackets styles.
Note: BSEE regards at water as primary firefighting tool; however, USCG regards the fire
extinguishers as the primary tool.
BSEE requires a fire water system installed on all manned facilities unless an approved wavier
has been appropriated
Portable Fire Extinguishers

1. All Fire Extinguishers shall have permanently attached durable name plate (UL Label)
giving the name, rated capacity and address of person/firm for who approved, and
manufacture are identification.
2. All Fire Extinguishers are required to be serviced and inspected annually by a NFPA
certified servicing company or NFPA Certified company personnel.
3. All excess firefighting equipment on the platform must be an approved type and serviced
and inspected the same as the required equipment.
4. All fire extinguishers shall be inspected monthly, inspection tag punched and inspection
documented and match the station bill as per type and size
Semi-Portable Fire Extinguishers:

1. All extinguishers shall have a permanently attached durable name plate (UL Label) giving
the name, rated capacity and address of person/firm for who approved and manufacture’s
identification.
All Fire Extinguishers are required to be serviced and inspected annually by a NFPA certified
servicing company or NFPA Certified company personnel
2. Semi-portable extinguishers shall be located in the open so as to be readily seen.
3. All fire extinguishers shall be inspected monthly, inspection tag punched and inspection
documented and match the station bill as per type and size
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TABLE 145.10(A)—PORTABLE AND SEMI-PORTABLE EXTINGUISHERS
Space Classification Quantity and location
SAFETY AREAS
Communicating corridors...................................... A–II .................... 1 in each main corridor not more
than 150 feet apart. (May be located in stairways.)
Radio room ............................................................ C–II .................... 1 in vicinity of exit.
ACCOMMODATIONS
Sleeping accommodations .................................... A–II .................... 1 in each sleeping
accommodation space. (Where occupied by more than 4 persons.)
SERVICES SPACES
Galleys .................................................................. B–II or C–II ........ 1 for each 2,500 square feet or
fraction thereof for hazards involved.
Storerooms ........................................................... A–II .................... 1 for each 2,500 square feet or
fraction thereof located in vicinity of exits, either inside or outside of spaces.
MACHINERY SPACES
Gas-fired boilers .................................................... B–II (CO2 or dry chemical). 2 required.
Gas-fired boilers .................................................... B–V .................... 1 required.1
Oil-fired boilers ......................................................B–II .................... 2 required.
Oil-fired boilers ......................................................B–V .................... 2 required.1
Internal combustion or gas turbine engines .... B–II .................... 1 for each engine.2
Electric motors or generators of open type .....C–II .................... 1 for each 2 motors or generators.
1 Not required where a fixed carbon dioxide system is installed.

2 When installation is on weather deck or open to atmosphere at all times 1 B–II for each three
engines is allowable.
3 Small electrical appliances, such as fans, etc., shall not be counted or used as basis for
determining number of extinguisher
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Subpart O
(PSST)
Training
Module
12
Out-of-Service Procedures
Temporary Out-of-Service Procedures
Regulations According to
30 CFR 250.803 (c) (1) API RP14C D.2
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The objective of this module is to provide attendees with an understanding of the
requirements for placing Safety Devices, equipment, components, control panels,
etc. in the By-Pass or Out-of-Service mode of operation.
This module will explain proper procedures for achieving the By-Pass mode of
operation including lock-out, proper tagging/flagging of equipment, Safety
Sensors and Safety Devices to ensure safe operation of the facility. Note: These
procedures shall not override Lessee operating procedures
SEMS and Lessee procedures requires that a Job Safety Analysis (JSA) be
performed, and documented with all affected persons before any testing
starts
Stop Work Authority
The authority is given to everyone to immediately stop work in progress when in

their best judgment they consider this action necessary, due to an observation at
risk behavior or unsafe condition that could cause injury, illness, and damage to
property or the environment.
Out-of-Service & Temporary Out-of-Service
General Requirements and Procedures for Production Safety Systems
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.
2. Only the minimum number of safety devices shall be taken out-of-service.
3. Personnel shall monitor the bypassed or blocked-out functions until the safety devices are
placed back in service, and
4. A surface or subsurface safety device which is temporarily out-of-service shall be flagged
with a visual indicator (tag) to identify the bypassed safety devices at the panel and the
manual isolation valves
For pipeline safety systems, 30 CFR 250.1004(c) allows pipelines to continue operating when
safety equipment has been rendered ineffective or removed from service only if:
1. An equivalent degree of safety is provided; and

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2. The safety equipment is identified by a sign placed on the equipment stating that the
equipment has been rendered ineffective or removed from service.
3. When wells are disconnected from producing facilities and blind flanged, equipped with a
tubing plug, or the master valves have been locked closed, you are not required to comply
with the provisions of API RP 14C (incorporated by reference as specified in the regulation
concerning the following:
• Automatic fail-close SSV's on wellhead assemblies, and
• The PSH and PSL shut-in sensors in flow lines 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.
• All open-ended lines connected to producing facilities and wells shall be plugged or
blind-flanged, except those lines designed to be open-ended such as flare or vent lines.
Definitions
Bypassed Safety Device means a safety device installed as part of the platform safety system
and rendered inoperable by a person’s action that prevents the safety device from performing
its design function.
Computer-Based Technology System (CBTS) means a computer-controlled electronic safety
system such as PLC, SCADA and Remote Terminal (Telemetry) Units (RTU’s).
Control Station means a location at which an operator is capable of monitoring and controlling
the production process equipment and platform safety system.
Essential Operating Conditions means operational status of all safety devices, liquid levels,
temperature, and flow rates and/or pressures on specific downstream components.
Non-Computer-Based System (NCBS) means a safety system that operates basically with
pneumatic instrument supply pressure.
Remote Site means a satellite or subordinate platform that is not connected to the parent
facility.
Temporary Out-of-Service Practices
This recommended safe practice requires personnel engaging in production safety systems
activities be issued out-of-service tags uniquely identifiable to each employee. The practice is to
be followed for placing surface safety devices temporarily out-of-service during platform start-
up, minor maintenance, or testing activities. It is designed to ensure tags are utilized to identify
safety devices placed in by-pass and that they are removed “only after” the Safety Sensor or
Safety Device is returned to the in-service mode of operation
Employee responsibilities are

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• During facility start-up, minor maintenance, and or testing activities, place

one of the assigned Out-of-Service Tags on the By-Pass valve/switch that is rendering the
Safety Sensor or Safety Device inoperative (Out-of-Service).
• Place only the minimum number of devices needed to perform the required task in By-
Pass while the work is in progress.
• Continuously monitor equipment at all times affected by the By-Passing of Safety Sensors
and Safety Devices.
• At the end of each day, collectively conduct a review of everyone’s tags to ensure a
Temporarily Out-of-Service Tag has not been inadvertently left on a Safety Sensor or
Safety Device.
Monitoring Temporary OOS Bypassed or Blocked Out Functions
• The person (operator) placing safety devices temporarily out-of-service is responsible for
the monitoring location (component, device or panel) of the by-passed device and its
function.
• The operator must be directly involved in monitoring the event while in by-pass and not
performing other duties.
• Monitoring shall occur on the same platform, same deck level of, the component, device
or panel of the bypassed or blocked out function.
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• The operator must have the ability to manually initiate shut-in action in the event of an
abnormal operating condition must be maintained to protect personnel, the environment
and equipment.
• Monitoring shall not be interrupted for reasons such as breaks, lunch or to greet
personnel arriving on the facility including BSEE, company personnel, third party
personnel, supervisors, etc.
• If monitoring must to be interrupted for any reason, the by-passed or blocked out
function(s) must be returned to the in-service mode of operation, or component/process
shut-in.
Monitoring Procedures for NCBS Bypassed Safety Devices

The acceptable procedures for monitoring NCBS by-passed safety devices are:
1. Positioning monitoring personnel at either the control panel for the bypassed safety device,
at the bypassed safety device, or at the component that the bypassed safety device would be
monitoring when in-service; and
2. Ensuring that monitoring personnel are able to view all relevant essential operating
conditions until all bypassed safety devices are placed back in service and be able to initiate
shut-in action in the event of an abnormal condition.
Monitoring Procedures for CBTS Bypassed Safety Devices
The acceptable procedures for monitoring CBTS by-passed safety devices at either a remote site
or a parent facility are:
1. Positioning monitoring personnel at a designated control station (until all by-passed safety
devices are placed back in service) that is capable of all of the following:
a. Displaying the status of the bypassed safety device and all relevant essential operating
conditions that affect the bypassed safety device, well, pipeline, and process component.
b. Controlling the production process equipment and the entire safety system.
c. Displaying a visual indicator when safety devices are placed in the by-passed mode.
d. Upon command, overriding the by-passed safety device and initiating shut-in action in the
event of an abnormal condition.
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Maintaining communications at all times between remote monitoring

personnel and the personnel performing maintenance or testing.
Well Out-of-Service Procedure

1. Flag or Tag “Out-of-Service” all safety devices for well(s) on control panel(s).
2. Block/Close, Chain, Flag/Tag the Bottom Manual Master Valve. An “Out-of-Service” sign
installed.
3. SCSSV hydraulic instrument control lines shall be bled down and disconnected. Panel and
Tree SCSSV instrument tubing connections shall be capped/plugged (both ends).
4. Continue to inspect/test SSSV as a plug every six (6) months.
5. Block and lock out the well incoming header valve then the FSV will not have to be tested
6. Update monthly BSEE Inspection paperwork to show “Well Out-of-Service”. Continue to
monitor casing pressure.
7. Compliance with API RP14C safety device testing is not required. (Except for
inspecting/testing of SSSV or Plug).
8. Only when the well is plugged & abandoned, shall the Safety Flow Diagram and
Safe Chart is amended to show OOS status.
30 CFR 250.180 (1) You must submit a report to the District Manager according to paragraphs (h)
and (i) of this section whenever production begins initially, whenever production ceases during
the last 180 days of the primary term, and whenever production resumes during the last 180
days of the primary term.
30 CFR 250.180 (g) If your lease is continued beyond its primary term, you must submit a report
to the District Manager under paragraphs (h) and (i) of this section whenever production begins
initially, whenever production ceases, whenever production resumes before the end of the 180-
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day period after having ceased, or whenever drilling or well-reworking operations begin before
the end of the 180-day period.
30 CFR 250.180 (h) The reports required by paragraphs (a) and (g) of this section must contain:
(1) Name of lessee or operator;
(2) The well number, lease number, area, and block;
(3) As appropriate, the unit agreement name and number; and
(4) A description of the operation and pertinent dates.
30 CFR 250.180 (i) You must submit the reports required by paragraphs (a) and (g) of this section
within the following timeframes:
(1) Initialization of production—within 5 days of initial production.
(2) Cessation of production—within 15 days after the first full month of zero production.
(3) Resumption of production—within 5 days of resuming production after ceasing

production under paragraph (i)(2) of this section.
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Pressure or Atmospheric Vessels “Out-of-Service” Procedures
1. Flag/Tag “Out-of-Service” all safety devices for vessel(s) on control panel(s).

2. Flag/Tag then Block/Close, Chain (or Blind Flange) all inlet valves and outlet Valve is
recommended. The PSV is an exception its isolation valve must remain open and
functional. The PSV cannot be isolated and must remain in service
3. Depressurize and place “Out-of-Service” sign on vessel(s).
4. Update monthly BSEE Inspection Paperwork to show “Vessel Out-of-Service” condition.
5. Continue to inspect/test and document PSV(s) for thermal protection.
6. Compliance with API RP 14C safety device testing is not required. Except for
inspection/testing of PSV(s); it must remain functional.
7. Only when Pressure or Atmospheric Vessels are disconnected-removed from the
production train, shall Safety Flow Diagram and SAFE Chart be updated to show “Out-of-
Service” condition.
Pipeline “Out-of-Service” Procedure
1. A out of service pipeline are those pipelines that have not been used to transport oil, natural
gas, sulfur or produced water for more than 30 consecutive days.
2. Flag/Tag “Out-of-Service” all safety devices for pipeline(s) on control panel(s).
recommended. The PSV is an exception; its isolation valve must remain open and functional.
4. The PSV cannot be isolated and must remain in service
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5. Depressurize and place “Out-of-Service” sign on pipeline

6. Update monthly BSEE Inspection Paperwork to show “Pipeline Out-of-Service” condition.
7. If pipeline is to remain out-of-service for 60 days (30 Days OOS then 30 Days before written
notice) starting from first day of OOS condition BSEE Regional Supervisor must be notified in
writing. Only when Pipelines are disconnected removed from the production train, shall
Safety Flow Diagram and SAFE Chart be updated to show “Out-of-Service” condition.
8. Continue to inspect/test and document PSV for thermal protection.
9. If pipeline taken “Out-of-Service” for more than 1 year it MUST be flushed and filled with
inhibited seawater (pickled – chemically treated) and documented on records.
10. Prior to the fifth (5) year of Pipeline being “Out-of-Service” a pipeline abandonment plan
and procedure must be submitted to BSEE Pipeline Division, completed and abandoned by
year 5.
11. Compliance with API RP 14C safety device testing is not required. Except for inspection
testing of PSV(s); it must remain functional.
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Pump Out of Service Procedure
1. Flag/Tag “Out-of-Service” all safety devices for pump(s) on control panel(s).

2. Close Off and Lockout (implementing LOTO procedures as required) supply gas or motor
control devices on pump and label “Out-of-Service”.
recommended. Except PSV isolation valves (PSV(s) must remain functional.
4. Depressurize and place “Out-of-Service” sign on pump.
5. Update monthly BSEE Inspection Paperwork to show “Pump Out-of-Service” condition.
6. Compliance with API RP 14C safety devices is not required on out-of-service pumps.
Except for inspection testing of PSV which must remain functional.
7. Only when Pumps are disconnected or removed from the production train shall Safety
Flow Diagram and SAFE Chart be updated to show “Out-of-Service” condition.
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Test and or Bulk Separator Not in Use Procedure

For Test Separator(s) that are temporarily not in use (due to no wells being tested).
If Test and or Bulk Separator is not in use and all safety devices are “in-service”
• Status remains normal.

or
If Test / Bulk Separator is not in use and safety devices are tripped (placed) out-of-service:
• Flag or Tag “Out-of-Service” Test / Bulk Separator relay(s) on control panel(s).
• The inlet valve (manual or automatic SDV) must be closed.
• Continue to inspect/test and document all safety devices as normal.
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Temporary Out-of-Service Procedure

• To be used only during platform start-up, minor maintenance and or testing activities.
1. Properly flag and tag safety devices before placing temporarily out-of-service utilizing
temporary out-of-service tag procedure.
2. Only the minimum number of safety devices shall be flagged/tagged and placed out-of-
service.
3. Personnel shall continually monitor bypassed or blocked out functions until safety devices
are placed back in service.
4. Upon completion of start-up, minor maintenance and /or testing, all safety devices shall
be returned to the “in-service condition” and flag/tags removed.
Caution: When placing safety devices in By-Pass, certain precautions should be taken to insure
that no other group or groups of safety devices are inadvertently placed out-of-service.
Some safety systems panels may not allow for individual isolation of components and or safety
devices. In these cases, other trains components safety devices will also be “out-of-service” (By-
Passed). When this occurs, those components and associated safety devices must also be
monitored until they are placed back in-service.
Additional personnel may be required to monitor each component and/or device(s) placed out-
of-service in order to comply with the regulatory requirements.
Example (Loss of Liquid Level – Level Safety Low Indicated)

A loss of liquid level occurs within a Fuel Gas Scrubber, Compressor Suction Scrubber,
Production Separator, etc. that causes the Level Safety Low (LSL) device to trip out.
1. Properly flag/tag safety device(s) before placing temporarily out-of-service utilizing

temporary out-of-service tag(s) / procedure.
2. Place only minimum number of safety devices temporarily out-of-service.
3. Person(s) shall continually monitor bypassed or blocked out functions until safety devices
are placed back in-service.
Under no circumstances shall the work area be left unattended while
safety devices are in by-pass.
4. Block/Close manual liquid outlet valve(s) to re-establish the normal operating liquid level
and clear (return to normal operating status) the LSL safety device.
5. Vessel must be monitored until the level is re-established and the LSL is cleared or
returned to its normal function.
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6. Should re-establishing a level require an extended period of time, one of the following
must occur:
a. Continue to monitor until level is re-established or
b. Apply for BSEE waiver approval or
c. Place vessel out-of-service as per out-of-service procedure.
7. Upon re-establishing liquid level and satisfying the LSL, all safety devices and isolated
valves(s) shall be returned to the “in-service condition” and flags/tags removed.
Temporary Out-of-Service Monitoring Example #1: Loss of Liquid Level
You are an operator and alone on the platform. The platform alarm sounds and the Master
Control Panel (which is located on the top deck), is indicating a LSL has occurred in the Fuel Gas
Scrubber (which is located on the deck below). The Fuel Gas Shutdown Group on the Master
Panel consists of a Manual Reset Relay, First-Out Indicators and a Bypass Valve for each of the
following end devices: PSH, PSL, LSH, and LSL. Further investigation will determine that the
Level Control Valve (LCV - dump valve) is operating properly, but the Level Controller was
improperly set. It has dumped (discharged) the liquid level below the normal operating level of
the LSL. From past experience you know that this Scrubber will take at least 1 hour to re-
establish a normal liquid level.
Correct Action and Response:
1. Respond to alarm by walking to Master Panel, silencing alarm (do not reset panel).
2. Walk down to deck below, investigate problem determining if a LSL (Level Safety Low)
does in fact exist in vessel and there are no external leaks or ruptures. At this point you
are unsure if you have a Level Control Valve (LCV - dump valve) or a Level Controller
problem.
3. Flag/Tag (recommended practice) before closing manual block valve on liquid outlet
(discharge) line.
4. Return to Master Panel, place temporary out-of-service tag(s) on LSL Bypass Valve (to
place LSL in bypass) and then reset Manual Reset Relay.
5. Return to vessel and determine if the problem is the Level Controller. Correct problem
(malfunction) with the Level Controller.
6. Continue to monitor vessel until the liquid level is re-established and the LSL comes back
in-service.
7. Once the level is re-established, open the manual block valve on the liquid outlet line and
verify proper Level Controller operation.
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8. Return to Master Panel, place or return the LSL By-Pass Valve to the “in-service”
placement and remove out of flags.
Temporary Out-of-Service Monitoring Example #2

Multiple Process Alarms
While working on the Fuel Gas Scrubber problem in Example #1 another alarm sounds at the
Master Panel. At this point, the correct action/response would be:
1. Respond to alarm by walking directly back to the Master Panel, silencing alarm (do not
reset panel).
2. Determine if second alarm requires immediate corrective action.
a. If immediate action is “not” required, leave it shut-in and return directly to Fuel Gas
Scrubber.
• Once the initial problem (Fuel Gas Scrubber) is corrected and all safety
devices are placed back in-service, then address or examine the second
alarm.
If immediate attention is required
• Determine which problem has priority.
• If the Fuel Gas Scrubber has priority, leave it shut-in and return directly to Fuel Gas
Scrubber
• If the second alarm has priority, place all devices on Fuel Gas Scrubber back in-
service, trip (push) Manual Reset Relay inward to close SDV for Fuel Gas Scrubber
and address second alarm.
Out-of-Service Procedure Review:
To be used only during facility start-up, minor maintenance and or testing

activities.
1. Properly flag/tag Safety Sensors and Safety Devices before placing Out-of-Service utilizing
temporary out-of-service tag procedure.
2. Only the minimum number of Safety Sensors and Safety Devices shall be flagged/tagged and
placed Out-of-Service at one time.
3. Personnel shall continually monitor By-Passed or blocked out functions until Safety Sensors
and Safety Devices are placed back in-service.
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3. Upon completion of start-up, minor maintenance and /or testing, all safety devices shall be
returned to the “in-service condition” and flag/tags removed.
Caution: Whenever placing Safety Sensors and Safety Devices in the By-Pass, mode of
operation, certain precautions should be taken to insure that no other group on groups of safety
devices are inadvertently placed out-of-service.
Some safety systems such as the Series Loop systems, may not allow for individual isolation of
components and or safety devices. In these cases, other trains components safety devices will
also be Out-of-Service (By-Passed). Whenever this occurs, those components and associated
safety devices must also be monitored until they are placed back in-service.
Additional personnel may be required to monitor each component and/or device(s) placed out-
of-service in order to comply with procedures or requirements.
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Subpart O
Training
Module
13
SEMS
Safety Regulations
API RP 75 SEMS October 2004
API RP 75 SEMS II June 2013

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Introduction
Safety and Environmental Management Systems - SEMS
BSEE Quote: “The SEMS is a nontraditional, performance-focused tool for integrating and
managing offshore operations. The purpose of SEMS is to enhance the safety of operations by
reducing the frequency and severity of accidents.
There are four principal SEMS objectives:
1. focus attention on the influences that human error and poor organization have on
accidents;
2. continuous improvement in the offshore industry's safety and environmental records;
3. encourage the use of performance-based operating practices; and
4. Collaborate with industry in efforts that promote the public interests of offshore worker
safety and environmental protection.”
In accordance with 30 CFR Section 250 and Subpart S 30 CFR 250 1910 Each Lessee must
develop, implement, and maintain a Safety and Environmental Management System (SEMS)
for all its offshore facilities and operations under Bureau of Safety and Environmental
Enforcement (BSEE) jurisdiction. The Lessee shall comply fully with this regulation and has
prepared this Management Control Document to define and implement its SEMS program.
The regulations fully incorporate the provisions of American Petroleum Institute Recommended
Practice 75 (API RP 75 Third Edition May 2004), except that those provisions have been made
mandatory.
Both the regulations and API RP 75 enumerate specific requirements in 17 elements.
The SEMS Regulations enumerate 17 different elements that must be implemented as part of a
SEMS program, as well as specific requirements that must also be put into practice. Lessee and
contractor both have a SEMS plan in which this is covered by a Bridging document. The SEMS
Plan outlines the requirements for the 17 elements of SEMS.
Note: The intention of this SEMS module does not replace any required SEMS training under the
guidelines issued by a governmental agency.
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The 17 elements of SEMS are as follows:
1. General Provision (30 CFR 250.1909)

2. Safety and Environmental Information (30 CFR 250.1910)
3. Hazards Analysis (30 CFR 250.1911)
4. Management of Change (30 CFR 250.1912)
5. Operating Procedures (30 CFR 250.1913)
6. Safe Work Practices (30 CFR 250.1914)
7. Training (30 CFR 250.1915)
8. Mechanical Integrity (Assurance of Quality and Mechanical Integrity of Critical
Equipment) (30 CFR 250.1916)
9. Pre-startup Review (30 CFR 250.1917)
10. Emergency Response and Control (30 CFR 250.1918)
11. Investigation of Incidents (30 CFR 250.1919)
12. Auditing (Audit of Safety and Environmental Management Program Elements (30
CFR 250.1920)
13. Recordkeeping (Records and Documentation) and additional BSEE requirements
(30 CFR 250.1928)
14. Stop Work Authority (SWA) (see §250.1930 General Provision (30 CFR 250.1930)
15. Ultimate Work Authority (UWA) (30 CFR 250.1931)
16. Employee Participation Plan (EPP) (30 CFR 250.1932)
17. Reporting Unsafe Working Conditions (30 CFR 250.1933
SEMS and Lessee requires that a Job Safety Analysis (JSA) be performed, and
documented with all affected persons before any testing, crane operations,
any repairs or done.
Stop Work Authority
The authority is given to everyone to immediately stop work in progress when in their best
judgment they consider this action necessary, due to an observation at risk behavior or unsafe
condition that could cause injury, illness, and damage to property or the environment.
Note: This module is just highlighting on the SEMS 17 Element requirements; it does not
replace SEMS Training Requirements
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The 17 SEMS Elements
Element 1 (General Provisions) 30 CFR 250.1900-1904, 250.1909 API RP 75,

Section 1
• This element addresses and describes in general the purpose, procedures, scope, and
objective of the program and lists the various elements of the program.
• Establish goals and performance measures, demand accountability for implementation,
and provide necessary resources for carrying out an effective SEMS program.
• Appoint management representatives who are responsible for establishing,
implementing, and maintaining and reporting to management an effective SEMS program.
• Review the SEMS program at specified intervals (at least annually) to determine if it
continues to be suitable, adequate, and effective. Document the observations, conclusions,
and recommendations of that review.
• Develop and endorse a written description of Lessee safety and environmental policies
and organizational structure that define responsibilities, authorities, and lines of
communication required to implement the SEMS program.
• Utilize personnel with expertise in identifying safety hazards, environmental impacts,
optimizing operations, developing safe work practices, developing training programs and
investigating incidents.
• Ensure that facilities are designed, constructed, maintained, monitored, and operated in a
manner compatible with applicable industry codes, consensus
• Establish and maintain a procedure to identify and have access to all references, industry
codes, practices and regulations
Element 2 (Safety & Environmental Information) 30 CFR 250.1910 API RP 75, Section 2
• This element addresses the safety and environmental information of a facility that must be
developed and maintained in support of the program.
• Process design information including, as appropriate: a simplified process flow diagram

acceptable upper and lower limits for operating parameters such as temperature,
pressure, flow and composition
• Mechanical design information including, as appropriate:
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• Piping and Instrumentation Diagrams (P & IDs)

• Electrical area classification drawings
• Equipment arrangement drawings
• Relief System Designs
• Description of the alarm, shutdown and interlock systems
• Description of the well control systems
• Design basis for passive and active fire protection features and systems and
• Emergency evacuation procedures
• Process Design Information
• Information on how considerations of human factors are evaluated during the design or
Installation of new facilities and major design modifications
Element 3 (Hazard Analysis) 30 CFR 250.1911 API RP 75, Section 3
• This element addresses the need for hazard analyses, Review and update as required hazard
analysis. Establishes the requirement for Job Safety Analyses (JSA) to be implemented for
job task and kept current on all LESSEE facilities.
• Conduct Hazard Analysis of all OCS Facilities
• Resolve any hazards found
• Perform a JSA which identify, analyze and record each job step, note any existing and or
potential safety and or health hazards associate with each step
• The supervisor must approve the JSA prior to work commencement
Element 4 (Management of Change) 30 CFR 250.1912 API RP 75, Section 4
• This element addresses management of change written procedures to identify and control
hazards associated with equipment, procedures, materials, or personnel.
• Modification procedures for equipment, procedures, material, personnel or contractor
changes, operating conditions
• MOC do not apply to any situations involving replacement in kind
• Management will review and approve
• Operations procedures must be documented, dated, reviewed periodically and conveyed to
all affected persons when changes are made.
Element 5 (Operating Procedures) 30 CFR 250.1913 API RP 75, Section 5
• This element addresses written operating procedures that provide instructions on how to
conduct activities in an efficient, safe and environmentally sound manner.
• Operating procedures to cover all aspects of operations
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• Operation procedures shall be accessible to ALL personnel involved in the operations

• Operation procedure manuals updated and reviewed by all personnel
• Operating Procedure Review (Verify all procedure reviews for Operating Procedure are
signed off by each crew on different pages)
• Operating Procedure Revision Review and updated (Verify all procedure reviews for
Operating Procedure are signed off by each crew on different pages)
Element 6 (Safe Work Practices) 30 CFR 250.1914 API RP 75, Section 6
• This element addresses safe work practices to limit risk associated with operational,
maintenance, modification activies, and any hazardous or toxic material uses. The element
also addresses contractor selection criteria.
• Safe Work Practices Guidelines (Lessee and contractor guidelines to safe work practices)
• JSA’s
• Marine Debris Hard Copy and Video (PDF format)
• Facility Orientations
• Contractor selection criteria (Safety Performance, Training, Injury and illness logs)
Element 7 (Training) 30 CFR 250.1915 API RP 75, Section 7
• This element addresses the training of employees and contractors involved in operations of
the company’s facilities to ensure that they are aware of performing safely and
environmental concerns. Verification that the employees and contractor are trained
• Well Control & Sub Part-O Training Plan
• Employee Training Records (Have hard copy on file for each person in field office)
• Contractor Training Records(Retrieval from contractor training department) Have hard
copy on file for each person in field office
• Basic Operator Training Guide (Tool for training operators.)
• Verify and document employee and contractor training, competency and work ethics
Element 8 (Quality Assurance & Mechanical Integrity) 30 CFR 250.1916 API RP 75, Section 8
• This element addresses and calls for written procedures to be in place so that critical
equipment for facilities are designed, installed, tested, inspected, monitored, and maintained
in a manner consistent with appropriate service requirements, manufacturer’s
recommendations, and industry standards. Critical equipment includes all equipment and
systems used to prevent or mitigate uncontrolled releases of hydrocarbons, toxic substances,
or other materials that may cause environmental or safety consequences.
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• Mechanical Integrity Reports (API RP 75 section 8)

• Any equipment modifications, documented, and conveyed to operation personnel on any
procedure changes
• Assurance that material , spare parts, equipment are suitable for that application
• Mechanical Integrity Contractor Link (Access to Mechanical Integrity, Topside, and
Underwater Inspections.)
• All compliance regulatory testing performed and documented
Element 9 (Pre-Startup Review) 30 CFR 250.1917 API RP 75, Section 9
• This element addresses and calls for a pre-startup review of new and significantly modified
facilities.
• Pre-Startup Form
• Pre-Startup Procedures
• Completed Pre-Startup Reviews
• Training of operating personnel
Element 10 (Emergency Response and Control) 30 CFR 250.1918 API RP 75, Section 10
• This element addresses the requirement for emergency response and control plans for
immediate implementation.
• Emergency Evacuation Plans (Site Specific Emergency Evacuation Plans)
• Oil Spill Response Plan
• Hurricane Evacuation Plan
• These plans must be conducted and each element exercised by drills as per plans and
documented
• Each drill must be analyzed, critiqued and documented to identify and correct any
weaknesses
Element 11 (Incident Investigation) 30 CFR 250.1919 API RP 75, Section 11
• This element addresses and establishes procedures for the investigation of all incidents with
serious safety or environmental consequences or potential conquences. Determine
document all casual factors and recommend appropriate corrective actions
• Incident Reporting Instructions
• Accident Reports (Web or hard copy based accident reporting.)
• Incident Report Forms (Excel Blanks, Near Miss, Root Cause Analysis, and Accident report)
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• Implement a system to distribute investigation findings to facilities and appropriate
personnel within their organization
Element 12 (Audit) 30 CFR 250.1920-1926 API RP 75, Section 12
• This element addresses the requirements and procedures for audits of the various program
elements including scope, the need for a written plan, frequency and the requirements of the
audit report. The goal is to ensure that all the elements is being effectively implemented and
most of all improve awareness, safety and environmental performance
• Sems Audit Plans
• Audited within two years of implementation of the program
• Audited every three years thereafter
• Audit of SEMS Program must be comprehensive of all thirteen (17) elements
• Audited by I3P (Independent Accredited Third Party) 30 CFR 250.1926
• Sems Audits to be sent to BSEE within thirty days of audit completion
• Deficiencies is to be corrected within thirty (30) days
Element 13 (Recordkeeping and Documentation) 30 CFR 250.1928 and 1929 API RP 75,
Section 13
• This element addresses and establishes record keeping and all documentation records
retention requirements
• Lessee must have a copy of all SEMS program documents at an on-shore location
• All records and documents relating to SEMS must be maintained for a period of six (6) years
• All audit documents must be kept for six (6) years
• All JSA’s documented must be kept at field office for thirty (30) days with a copy kept at the
onshore office for two (2) years
• All Management of Change provisions be kept for two (2) years
• Injury and Illness Logs kept for two years
• All contractors evaluations, safety policies and procedures for two (2) years
• Keep all records in an orderly manner, readily identifiable, retrievable, legible, and include all
dates of revisions
Element 13 - Libraries this info must be available to all persons at facilities, whether on a
web portal, operating procedure manuals,
• Blank Forms (Numerous Blank LESSEE forms. Which can be accessed on SEMS home page?)
• References and Regulations (Code of Federal Regulations, and American Petroleum
Institution Regulations. Can be accessed on SEMS home page.)
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• Scada Drawings (Instrumentation & Electrical drawings)
• Archived Document (Previous JSA’s)
Element 14 (Stop Work Authority) 30 CFR 250.1930 API RP 75, Section 14
• Stop Work Authority (14) has been revised to create procedures that establish Stop Work
Authority (SWA) and make responsible any and all personnel who witness an activity that is
creating imminent risk or danger to stop work. All persons have STOP WORK AUTHORITY 30
CFR 250.1930
Element 15 (Ultimate Work Authority) 30 CFR 250.1931 API RP 75, Section 15
• Ultimate Work Authority (15), Stop Work may be resumed when the lessee designated
individual on the facility with Ultimate Work Authority determines that the imminent risk or
danger does not exist or no longer exists. The decision to resume activities must be
documented in writing as soon as practicable 30 CFR 250.1931
Element 16 (Employee Participation Plan) 30 CFR 250.1932 API RP 75, Section 16
• Requiring an employee participation plan that provides an environment that promotes

participation by offshore industry employees as well as their management to eliminate or
mitigate safety hazards.
• Examples:
• Behavior Observation Card (BSOP)
• Safe Cards
• Safety meeting Participation
• JSA Meeting Participation
Element 17 (Stop Work Authority) 30 CFR 250.1933 API RP 75, Section 17
• Establishing guidelines for reporting unsafe working conditions that enable offshore industry
personnel to report possible violations of safety, environmental regulations requirements,
and threats of danger directly to BSEE
• Establishing additional requirements for conducting a job safety analysis ensuring JSA be
prepared, hazards identified, JSA meeting conducted, hazards communicated to affected
personnel and approval
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**NOTE**
Please review all of your facilities on the portal, field operating manuals and drawings to make
sure all of the above listed documents are present, and up to date.
Please review all of your facilities to make sure all of the listed action items have been corrected,
and/or provide the information needed to make corrections to SEMS Coordinator and Assigned
compliance regulatory persons
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Subpart-O
(PSST)
Training
Module
14
Safety Device
Test Procedures
(Hands on Device Testing)
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Safety Device - API RP 14C Test Procedures

Introduction
All safety devices must be tested according to the requirements (and within time periods or
schedules) listed within 30 CFR 250 and the recommendations of API RP 14C. The generalized
test procedures as provided are not all inclusive. Facility operators, instrument technicians
and others engaged in the testing of the safety devices or components should utilize the exact
test procedures as defined within the production facility operation manual or as detailed within
the manufacturer’s established guidelines for safety device testing.
Before each individual test is started for the safety devices, the control room and each operator
department affected must be notified that test will be conducted and the safety system or
specific items will be placed in the By-Pass (Testing) mode of operation. The test period start
and conclusion should be announced over the facility Public Address system. Whether the safety
system is Programmable Logic Controller based or the standard pneumatic/hydraulic pressure
operated components, testing should proceed in a manner that does not compromise the safe
operation of the facility.
Note: SEMS requires that A Job Safety Analysis (JSA) be conducted with the affected crew
members.
Note: All testing will required the appropriate OOS flagging at the master panel, control
station, and any valves closed or moved for testing purposes like SCSSV Tree needle valve,
LSHL Bridle Valves, because in essence you are placing these devices out of service. Follow
all Lessee OOS Flagging Procedures
A generic listing of the test procedures for the most common type of safety devices is provided
next.
A. Burner Safety Low (BSL - Flame Failure Detector)
1. To check pilot light flame failure control:

a. Light Pilot Burner.
b. Block fuel supply to main Burner.
c. Shut off fuel supply to Pilot Burner and check BSL for proper detection response.
2. To check burner flame-out control:
a. Light main burner.
b. Block fuel supply to pilot light.
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c. Shut off fuel supply to main burner and check BSL for proper detection response.
d. Verify all fuel gas shutoff.
3. Record (document) test results appropriately.
B. Analyzer Safety High (ASH - Combustible Gas Detector).
1. Adjust the zero control, if necessary; so that meter reads 0% LEL with all gas positively
eliminated from sensor probe inlet.
2. Place sensing adapter of portable purge calibrator over probe head inlet and open
shut-off valve on test gas sample container.
3. When ASH meter reaches maximum level and stabilizes, record indicator meter
reading, calibration gas concentration, low alarm and high shut down set points (%
LEL).
4. If necessary, adjust ASH meter to read % LEL of calibration gas.
5. Close shut-off valve on test gas sample container and remove sensing adapter.
6. Adjust test control or zero control (as appropriate) and observe low and high trip
points (response settings) on ASH indicator. Check shutdown relay for proper
actuation.
Note: The published maximum of Alarm at 25% LEL and Shut-in at 60% LEL cannot be
exceeded in final setting and condition response of the ASH.
C. Emergency Shut Down System (ESD).
1. Operate a manual remote station, preferably one on thirty (30) day or monthly
inspection basis that is next in line as per monthly inspection report, and observe that
the appropriate shut-in ESD relays or assembly operates properly. In other words a
different one each month
This may be done individually or as a group, depending on platform design, in order to
avoid actual platform shutdown, unless desired. Record the time (in seconds) after
operating the manual remote ESD station for a specific flow-line Surface Safety Valve
(SSV) (being tested) to close then time out the SCSSV closure time after the last SSV
has closed
2. Check each ESD station by moving valve handle to the shutdown position. Observe for
free ESD valve (unrestricted) movement and unobstructed instrument pressure
exhaust (bleed). Limit the exhaust actuation to prevent actual shutdown.
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D. Flow Safety Valve (FSV - Check Valve).
1. Close off upstream flow control valve and associated Header Valves.
2. Open exhaust (bleeder) control valve and exhaust (bleed) or depressurize pressure
from flow line segment or section between closed control valves.
3. Close exhaust (bleeder) function valve.
4. Open appropriate Header control valve.
5. Open exhaust (bleeder) valve.
6. Check exhaust (bleed) valve for back flow (pressure). If there is a continuous backflow
from bleeder valve, measure the flow rate. Rate should not exceed 200 cc/min. or 5
cubic feet/minute.
7. Close exhaust (bleeder) valve, re-open upstream control valve and resume normal
flow.
E. High and Low Level Sensors (LSH) and (LSL)
1. Close both manual bridle isolating valves from vessel to the outside float cage
assemblies.
2. Open exhaust or vent valve above LSH to exhaust internal pressure.
3. Fill cages(s) with outside fluid source or increase liquid level to high-level trip point.
4. Observe LSH at control panel for correct test response.
5. Drain cage or decrease fluid level by opening bottom drain valve until the low-level
LSL trip point is achieved
6. Recheck panel for correct test response
7. Reopen both outside float cage manual isolation valves slowly to refill and
repressurize the float cage assemblies and resume normal operation.
8. Record (document) LSH & LSL test results on monthly test inspection report
• Alternate, Outside Float Cage LSH & LSL Test Procedures using Vessel’s internal fluid
contents).
1. Close manual isolation valve between the vessel and the float cage assembly.
2. Drain float cage assembly, fluid level to low-level (LSL) trip point.
3. Open the lower isolating valve beneath the float cage assembly.
4. Slowly drain pressure on the top of the float cage assembly, allowing the vessel’s
pressure to push fluid contents upward from inside the vessel to the high-level (LSH)
trip point.
5. Close upper isolating valve of the float cage assembly after testing is complete.
6. Record (document) LSH & LSL test results appropriately.
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F. High and Low Pressure Sensors (PSH and PSL)
1. Close vessel’s isolating valve below the Pressure Sensor manifold connection.
2. Apply increasing test pressure to sensor(s) test connection assembly, with a hydraulic
test pump, high-pressure natural gas or Nitrogen to test PSH. Adjust the Pressure
Sensor as necessary. Record high sensor’s (PSH) trip pressure.
1. If sensors are installed in series with the high sensor (PSH) upstream from the low
sensor (PSL), exhaust test pressure to reset the high sensor (PSH). Continue to
decrease the test pressure from sensors until PSL (low pressure) actuation is achieved.
Adjust the Pressure Sensor as necessary. Record the low sensor’s (PSL) trip pressure.
2. Open the manual isolation valve beneath the sensor’s manifold block assembly to
restore normal operating pressure.
G. Pressure Safety Valve (PSV - Relief Valve)
1. Remove lock or seal mechanism, close off the PSV inlet manual isolating, block valve
located beneath the PSV assembly.
2. Connect test connection assembly to the PSV test port. Check what is the PSV set
pressure for a guide. Apply increasing test pressure through test connection with
Nitrogen, high-pressure gas or hydraulic pump test system. Record pressure at which
the PSV (relief valve or external test/control pilot) starts to relieve or discharge test
pressure.
3. The Pressure Safety Valve (or test pilot) should continue relieving pressure until the
decreasing reseat pressure is achieved or the PSV returns to a close-to-flow
placement. Keep test connection intact or in place until the Pressure Safety Valve
operates (discharges) at the exact Pressure Setting required.
4. Once the exact PSV Pressure Setting is achieved, reopen inlet isolating block valve.
Lock or seal the full ported isolating valve in the open to flow placement.
5. Tag and record (document) the PSV test results appropriately.
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H. Pipeline and Process Equipment Shutdown Valve (SDV)

Tested for operation only
Option 1 - Partial Close Operation Test
1. Exhaust (Bleed) pressure off the appropriate SDV Actuator and allow valve to reach
three-quarter closed position. Normally a three-way, test Ball Valve is provided for
testing.
2. Observe the appropriate SDV Actuator for proper actuation.
3. Return normal operating, instrument supply operating pressure to SDV Actuator.
4. Record (document) the SDV test results appropriately.
Option 2 - Fully Closed Valve Test
1. Exhaust (Bleed) pressure off the appropriate SDV Actuator through the initiation
signal (to fully close SDV) from either a remote or local switch/valve.
2. Observe the appropriate SDV Actuator for proper fully closed-to-flow actuation.
3. Return normal operating, instrument supply operating pressure to SDV Actuator.
4. Record (document) the SDV test results appropriately.
I. Surface Safety Valve (SSV)

Pressure Holding Leakage Test.
1. Shut-in wellhead to be tested (close the well to normal flow).

2. Close the SSV to be tested to internal flow. Observe the SSV for proper closing
actuation.
3. Open the wing and flow line’s manual valves to permit internal pressure to be bled
off or exhausted off from the upstream SSV.
4. With pressure on upstream side of the closed-to-flow SSV, open manual valve
downstream of SSV.
5. Check for flow or leakage. If there is any leakage, the SSV must be repaired or
replaced. No leakage allowed.
6. Reopen the appropriate manual isolation valves and the SSV of well assembly being
tested.
7. Return the well to normal production flow.
8. Record (document) the SSV test results appropriately.
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J. High and Low Temperature (TSHL)

Operation Test.
1. Adjust the Temperature Setting (set point) indicator until Temperature Controller
being tested actuates properly (trips).
2. Reset Temperature Controller tested to the Temperature Setting (set point) base
on observed temperature indicator as follows:
(a) For an Indicating Temperature Controller: Add or subtract the difference

between indicated temperature and trip temperature to the desired trip
temperature.
(b) For a Non-indicating Temperature Controller with graduated dials: Add or

subtract the difference between dial reading at trip point and actual temperature
to calculate the desired trip setting.
(c) For Devices that neither indicate nor have graduated dials – Reset according to
manufacturer’s instructions.
K. High and Low Temperature (TSHL)
Temperature Bath (Test Fixture Assembly) Test.
1. Remove only the temperature-sensing probe of the Temperature Controller to be

tested, from the thermowell located in process component.
2. Place a Thermometer within a hot liquid test bath media assembly to verify
temperature.
3. Insert temperature-sensing probe of the Temperature Controller in the liquid test
bath media assembly.
4. Set the manual dial on Temperature Controller to the same temperature indicated
on the Thermometer within the test bath media assembly.
5. Record High Temperature set point that is attained. If the Temperature Controller
does not trip (actuate to loose instrument output pressure or signal at the
temperature of the liquid test bath media), adjust or calibrate the Temperature
Controller to trip at that indicating temperature.
6. Remove the Temperature Controller’s temperature sensing probe from liquid bath
media. Allow it to cool to ambient temperature.
7. Record (document) the TSH test results appropriately.
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8. Return the sensing probe assembly to its original location and adjust the
Temperature Controller to it required operating temperature.
L. High Temperature (TSH) Ex-Line
Temperature Safety High Test (Ex-Line)
1. Remove instrument tubing or micro switch, Verify master panel tripped as

required.
2. Test micro switch if installed for operation,

3. Unscrew ex-line and verify temperature rating marked on Ex-line as per
documentation set temperature
4. Document setting, reinstall in reverse
5. Verify all is back in service
M. Underwater Safety Valve (USV)
Combined Operation and Leakage Test. See Table D-2 Item M SSV Inspection
NTL 2009 -36
Deepwater Operations Procedure Plan
Note: The USV is a highly specialized component and it requires testing according to specific
test procedures established and detailed within the facility operating manual. The test
procedures must thoroughly studied in advance of actual testing to ensure proper operation.
Follow the deep water operation procedure plan.
Leakage rate for the USV is 400 cm Liquid and or 15 cf gases
Each operator should use a test method appropriate to the USV operating system that
demonstrates the proper pressure integrity of the USV and quantifies any leakage rates. As with
all testing of safety devices, the test result must be properly recorded and documented.
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Safety Device Testing Hands Device on Procedure to test for SCSSV Control
line leak
• Surface Control Sub Surface Safety Valve (SCSSV).

• E.1 Procedure for testing installed SCSSV Standard Depth
• E.1.1 Record the control pressure
• E.1.2 Isolate the control system from the wellhead to be tested.
• E.1.2 Shut the well in at the wellhead
• E.1.4 Wait a minimum of 5 min. Check the control line for loss of pressure which may
indicate a leak in the system
• E.1.5 Bleed the control line pressure to zero to shut in the SCSSV. Close the control line
system and observe for pressure buildup, which may indicate a faulty SCSSV System
Safety Device Testing Hands Device on Procedure to Test for SCSSV and Plug
Check
SCSSV and Plug Check Testing Procedure

1. Shut In wellhead at the wing valve or Surface Safety Valve #2 (SSV) and leave SSV #1 open
2. Stabilize well to get an accurate Shut In Tubing Pressure (SITP) and document pressure
3. Conduct SCSSV control line pressure test and document results
4. Verify SCSSV is closed, Bleed off at least 20% of the SITP and record this resulting
pressure.
5. Monitor the pressure for a reasonable amount of time unless starting at Zero the wait five
minutes
6. Verify this ending pressure and document results
7. Check leakage rate, If leakage is in specs return well to hydrocarbon production
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PSST Training Student Manual Index

A
Abbeviations Safety Devices 63
Access To Facilities 100
Activation Times ESD, SCSSV, SDV, All Others (Complete Closure Time) 151
Analyzer Safety High (ASH) (Gas Combustible Detector) 16, 188
API RP 14C Accomplish Basic Protection Task (Primary & Secondary) 15, 96
API RP 14C Guidelines - Analysis, Design, Installation, Testing 14, 96
API RP 14C Incorporated By Reference Law (30 CFR 250.198) 14, 86
API RP 14C Primary Purpose - Information 15, 96
API RP 14C Regulations 14
ASME Pressure Coded Vessels (Identification Plate) 142
B
Balloon Safety Device Location Exercise Sheet 198, 199
Balloon Symbol Safety Device Identification 56, 58
Best Available And Safest Technologies (BAST) 107
Blow Down Valve (BDV) 18, 188
Boarding Shut Down Valve (BSDV) 19
BSEE Governmental Enforcement Agency 2
BSEE Inspection Fees 101
Burner Safety Low (BSL/TSL) 19
C
Casing Management, Diagnostic, Departure Subpart-E 113
Civil Penalties Subpart-N 129
Code of Federal Regulations 12, 97
Combustible Gas Detection Systems 89
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Component Identifiers 61, 62
Compressors & Compressor Safety Devices 143
Containment Systems (Decks, Skids, Sumps) 91
Control Relay Block And Bleed Manual (CRBBM) 21, 189
Crane Operations API RP 2D (Operation and Maintenance Of Cranes) 101
D
Deck Openings (Open Holes) 211
Departures and Waivers 13
Diesel Engine (Insulation, Air Intake Shut Downs, Spark Arrestors) 120
E
Electrical Systems (Classification and Installation Codes) 104, 146
Emergency Evacuation Plan (EEP)
24, 81, 86, 119,
Emergency Shut Down & Stations (ESD) API 14C Table C.1.12
142, 190
Emergency Support System (ESS) 21,
Enclosed Classified Areas 89
Engines Exhaust, Insulation, Air Intake 143
F
Facility Identification 98
Fire & Gas Detection Systems 144
Fire Detection Systems 87
Fire Pump Test Frequency 150
Fire water Pump (Run Time) 144
Flame Arrestor (FA) 25
Flaring and Venting (Max Vent Time) 125
Flaring and Venting Systems 93
Flow Safety High (FSH) 27
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Flow Safety Low (FSL) 27
Flow Safety Valve (FSV) (Check Valve) 28,190
Flowing Tubing Pressure, Shut In Tubing Pressure (FTP, SITP) 29
G
Guards and Rails Requirements 211
General Oral Approvals
Glycol Dehydration Units Safety Devices 143
Grounding Requirements 103
H
H2S Contingency Plan 36, 90, 109, 110
H2S Training Requirements 111
H2S 24 Hour Visit Person Requirements 112
H2S Facility Drills 112
Heliport Identification 99
High Pressure, Detectable 67
Hot Surface Contact and Protection From Contact 14
Hot Work & Device Permit, Fire Watch 102
I
Insulation Requirements 14
Ionization Safety High (YSH) 55
J
JSA Job Safety Analysis Example 218, 234
L
Leakage Review 150
Level Safety High, LSH (Pneumatic) 31, 191
Level Safety Low, LSH, (Electronic) 31, 191
Level Safety High, LSL (Pneumatic) 31, 191
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Level Safety Low, LSL, (Electronic) 31, 191
Lock Out, Tag Out , LOTO 209
Lower Explosive Limit (UEL, LEL, Detection Systems) 30
M
Manual Reset Mode (Relays, Safety Devices Sensors) 78
Maximum Allowable Operating Pressure (MAOP) 35
Maximum Allowable Working Pressure (MAWP) 35
Multiple Alarms Monitoring and Acting Lawfully
N
Notice To Lessee (NTL) 12
NPDES (National Pollutant Discharge Elimination System) 107
O
Oil Spill Reporting 106
Oral Approvals 98
Orientation Example 205
Other Support Systems 93
Out of Services Procedures Safety Device By-Passing, Employee 220
Out of Services Procedures Safety Device Monitoring Procedures 221 Thru 231
Out of Services Procedures Safety Device Temporary Monitoring 220
Out of Services Procedures, Employee OOS Responsibilities, Flagging 220
Out of Services Procedures, General, Objectives, Procedures, Multiple 146
Oxygen Safety High (OSH) Toxic Detectors 36

P
Pipelines DOI, DOT, Definitions 123
Pipelines Out Of Service Schedules 124
Platform Facility Identification 98
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Pollution Inspections Daily 108
Pollution Prevention and Oil Spill Drills, Training, Plans 105
Pollution Reporting 106
Pollution Responsibility Lessee 106
Potential Incident Of Non-Compliance (PINC) 13
Pressure Safety High (PSH) (PSHL) (Electronic) 36, 38, 192,
Pressure Safety High (PSH) (PSHL) (Pneumatic) 36, 38, 192
Pressure Safety High, Low (PSHL) Dead Band Description 139
Pressure Safety High, Low (PSHL) Settings + or - 15% or 5 psi 133, 140
Pressure Safety High, Low (PSHL) Settings 5 psi Rule 138
Pressure Safety High, Low (PSHL) Test Tolerance + or - 5% or 5 psi 138, 140
Pressure Safety High, Low, PSHL, HOP and LOP Determination, Range Chart 133
Pressure Safety High, Low, PSHL, Rounding Requirements 135
Pressure Safety Low (PSL) (PSHL) (Electronic) 38
Pressure Safety Low (PSL) (PSHL) (Pneumatic) 38, 192
Pressure Safety Valve (PSV – PVSV) (PSE - Rupture Disc) 40, 192
Pressure Safety Valve (PSV) Discharge Location 40
Pressure Safety Valve (PSV) Isolation Valve 39
Pressure Safety Valve (PSV) Max Setting 40
Pressure Safety Valve (PSV) Test Tolerance 131, 140
Process Component 35
Process Variables 56, 66
Production Measurement Commingling & Security Definitions 126
Production Measurement Commingling & Security Meter Seals 127
Production Measurement Commingling & Security Oil Meters Run Tickets 127
Production Measurement Commingling & Security Proving Requirements 127
Production Measurement Commingling & Security Royalty Tank ID 127
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PSHL ,PSV , Test Setting and Test Tolerance Cheat Sheet 140
PSV. PSHL, Range Chart Recorder Sensing Location 133
Q
Qualified Person 41
R
Record Keeping of Inspection and Test Results (Years) 152
S
Safe & Work Man Like Operations 100
Safety Analysis Checklist (SAC) API 14C Table B-1 41, 42, 154, 162
Safety Analysis Function Evaluation (Safe Chart) 42, 156, 157, 161
Safety Analysis Table (SAT) 43, 154
Safety Device Symbols and Identification 56, 58
SEMS Safety and Environmental Management Systems 233

Shut Down Valve (SDV) 47, 193
Standard Process And Safety Component Definitions 82
Safety Sensor Function, Manual Reset Mode 78
Station Bill 205
Stop Work Authority 218, 234
Sub Surface Control Subsurface Safety Valve (SSCSV) 45, 92
Sub Surface Control Subsurface Safety Valve (SSCSV) Test Schedule 46
Subpart-O Training, T-2 Training 129
Subsurface Control Safety Valves (SSSV) General Description 120, 194
Subsurface Control Safety Valves (SSSV) Depth Requirement 44, 121
Subsurface Control Safety Valves (SSSV) Removal Operator Attendance 121
Surface Control Subsurface Safety Valve (SCSSV) (Hydraulic Fluid Powered) 43, 120
Surface Safety Valve (SSV) 48, 193
Surface Safety Valve (SSV) Activation 48
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T
Temperature Safety Element (TSE) 49 145, 194
Temperature Safety Element (TSE) TSE Table C-1 Guidelines 87, 88
Temperature Safety High (TSH) 50, 195
Test Frequencies, Test Schedule, Leakage Rates, (All Safety Devices) 149
Test Frequency Schedule, Chart (All Safety Devices) 150
U
Ultraviolet Safety High (USH) 52
Underwater Safety Valve (USV) 53
Undesirable Event 66
Undesirable Event API 14C Chart 77
Undesirable Event (1) (Overpressure) 67
Undesirable Event (2) (Underpressure) 68
Undesirable Event (3) (Leak) 69
Undesirable Event (4) (Liquid Overflow) 70
Undesirable Event (5) (Gas Blowby) 71
Undesirable Event (6) (Excess Temperature, Fired and Heated Components) 73
Undesirable Event (7) (Direct Ignition Source) 74

Undesirable Event (8) (Excess Combustible Vapors In a Firing Chamber) 75
USCG Regulations
Attending Vessel 201
Emergency Drills 206
Emergency Evacuation Plan (EEP) 201
Fire Extinguisher, Classification, Inspections Reports, Servicing 215
General Alarms, Muster Stations 206
Life Saving Equipment , Unmanned 214
Life Saving Equipment, Manned 207, 211
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Manned & Unmanned Facility 202
Means Of Escape 210

Memorandum Of Understanding 201
Navigational Aids 210
Person In Charge (PIC) 102
Personal Protection Equipment (PPE) 208
Ring Buoys, Manned 213
Ring Buoys, Unmanned 214
Station Bill, Facility 205
USCG 5432 Self Inspection Report 202, 203, 204
V
W
Waste Management, Open Container Burning, Garbage Log 207
Web Sites Links Regulations 9
Wellhead Identification 99
Well Testing (Allocated Wells) Subpart K 126
Well Testing (Non-Allocated Wells) Subpart K 126
X
Y
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PSST (T-2) Training Student Manual

Student Training Manual

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Training Objectives ............................................................................................................................... 06

Regulatory Abbreviations .................................................................................................................... 07

Regulatory References-Governmental Links Web Sites ................................................................ 08

Module One (1) ..................................................................................................................................... 11

Module Two (2) ..................................................................................................................................... 65

Module Three (3) ................................................................................................................................. 80

TSE (Temperature Safety Element) Guidelines ............................................................................ 88

Module Four (4) ................................................................................................................................... 95

Module Five (5) .................................................................................................................................... 130

Module Six (6) ...................................................................................................................................... 141

Module Seven (7) ................................................................................................................................ 148

Module Eight (8) .................................................................................................................................. 153

Module Nine (9) ................................................................................................................................... 187

Module Ten (10) ................................................................................................................................... 197

Module Eleven (11).............................................................................................................................. 200

Module Twelve (12) ............................................................................................................................. 217

Module Thirteen (13) .......................................................................................................................... 232

Module Twelve (14) ............................................................................................................................. 242

PSST Training Manual Table of Contents...................................................................................... 251

Welcome, Orientation & Sign In

• Course Title: T-2 Subpart-O (PSST)

• Emergency Procedures & Exits

• Cell Phones on Silent and or Vibrate,

• No Cell Phone Texting while in class

• Course Requirements and Class Times

• Breaks & Lunch Time

• Break Room and Rest Rooms

• Smoking in Designated Areas

• Three (3) Year Certification

Course Description and Objectives

Method of Presentation and Evaluation

• The instructor will communicate what is expected in the hands-on exercises

• Demonstrate an understanding of the Oil & Gas Production Process

• Show familiarity with the regulations relative to PSST

• Six (6) years of offshore (OCS) oilfield experience

BSEE (Bureau of Safety and Environmental Enforcement) www.bsee.gov

Gulf of Mexico Region

• API Link: http://api.org

THIS PAGE WAS INTENTIONALLY LEFT

Safety Devices, Safety Device Symbols

A collection of federal laws (regulations) compiled by a branch of the Department of Interior

• Notices to Lessees and Operators (NTLs)

NTL’s are formal documents that provide clarification, description, supplement

- Provides guidelines on the implementation of a special lease stipulation or regional

- Provides a better understanding of the scope and meaning of a regulation by explaining

Potential Incidents of Non-Compliance (PINC)

Field PINC List (Below List)

Office PINC Same Letters 800+ Decommissioning - A

Example: INC = Incident Of Non-Compliance Violation P-103

American Petroleum Institute, Recommend Practice 14C (API RP 14C) is a private

What subjects are referenced in API RP 14C?

Other locations to get regulatory information (See Web Links)

What’s it the primary purpose of the platform safety system information

What other information is provided in API RP 14C?

How does it accomplish the basic protection task?

ASH - Analyzer Safety High (Combustible Gas Detector)

Test Frequency Requirement:

The ASH must be tested every 3 months,

BDV - Blow Down Valve