PROJECT ASSET INTEGRITY PLAN

(EPCIC EXECUTE PHASE) FOR

PEGAGA DEVELOPMENT PROJECT

Disclaimer: This document has been developed specifically for EPCIC of Pegaga Project
C3 21.07.2020 Approved for Construction (Re-AFC)
C2 26.08.2019 Approved for Construction (Re-AFC)
C1 18.03.2019 Approved for Construction (AFC)
4.4 19.10.2018 Issue for Approval (IFA)
4.3 30.07.2018 Re-Issue for Review (Re-IFR)
4.2 21.03.2018 Issue for Review (IFR)
4.1 19.03.2018 Inter-Discipline Check (IDC)

Rev No.
Date Purpose of Issue
 REVISON CHANGE HISTORY

All major changes to the document at this current revision are recorded below.
(Does not include correction of typos or formatting changes)

Revision: Date: Originator/ Author: Description of Change:

4.2 21.03.18 Mohd Zaieri Bin

Mohamed Issue for Review

Re-Issue for Review (Re-IFR) due to Code

Mohd Zaieri Bin ‘C’ received in Rev. 4.2. This document
4.3 30.07.18
Mohamed has been reviewed in advance by
COMPANY.

Mohd Zaieri Bin Issue for Approval (IFA)

4.4 19.10.18
Mohamed Incorporating Re-IFR comments.

Approved for Construction (AFC)

Mohd Zaieri Bin Incorporating IFA comments. This
C1 13.01.19
Mohamed document has been reviewed in advance
by COMPANY.

Re-Approved for Construction (Re-AFC)

Mohd Zaieri Bin Incorporating AFC comments. This
C2 26.08.19
Mohamed document has been reviewed in advance
by COMPANY.

Re-AFC
Mohd Zaieri Bin Incorporating Re-AFC comments. This
C3 21.07.20
Mohamed document has been reviewed in advance
by COMPANY.

HOLD LIST

Hold No. Description Status

Page 2 of 44
 TABLE OF CONTENTS

1 INTRODUCTION ............................................................................................................... 6
1.1 Project Background ............................................................................................ 6
1.2 Facility Description ............................................................................................. 6
1.3 Purpose of Document ......................................................................................... 7
1.4 Scope of Document............................................................................................. 7
1.5 Reference............................................................................................................. 7
2 DEFINITIONS AND ABBREVIATIONS ................................................................. 8
2.1 Definitions ........................................................................................................... 8
2.2 Abbreviations ...................................................................................................... 11
3 ASSET INTEGRITY REQUIREMENTS FOR EXECUTE PHASE ........................ 13
3.1 CONTRACTOR Asset Integrity Scope for EPCIC Execute Phase ....................... 13
3.2 Asset Integrity Plan ............................................................................................. 14
3.3 Asset Integrity Road Map .................................................................................... 15
4 ASSET INTEGRITY ACTIVITIES ........................................................................ 17
4.1 Project Validation ................................................................................................ 17
4.2 Leadership and Accountability ............................................................................. 18
4.3 Laws and Regulations ......................................................................................... 19
4.4 Codes and Standards.......................................................................................... 19
4.5 Performance Evaluation ...................................................................................... 19
4.5.1 Key Performance Indicators (KPI) .................................................................... 19
4.5.2 Implementation of Quality Assurance/ Quality Control (QA/QC) ................... 22
4.5.3 Inspections and Audits ........................................................................................ 22
4.5.3.2 Audits ................................................................................................................. 22
4.5.4 Management Review........................................................................................... 22
4.6 Management of Change/ Deviations ................................................................... 23
4.7 Risk Management ............................................................................................... 24
4.8 Barriers for Safety in design ................................................................................ 25
4.8.1 Safety Studies during Detailed Design Engineering (DDE) ............................ 25
4.8.2 Development of Safety Critical Elements (SCE) and PS................................. 26
4.8.2.1 Safety Critical Elements (SCE) ......................................................................... 27
4.8.2.2 Performance Standards (PS) ............................................................................ 27
4.9 Life Cycle Cost (LCC) in Procurement process for Type 1 Equipment ................. 27
5 CORROSION, ASSET INTEGRITY AND INSPECTIONS PROGRAMME ........... 28
5.1 Corrosion Risk Assessment (CRA)...................................................................... 28
5.2 Risk-Based Assessment and Inspection Programme .......................................... 29
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5.3 Inspection Requirements/ Baseline Inspection Requirements ............................. 30
5.3.1 Baseline Inspection for Pressure Equipment .................................................................... 30
5.3.2 Underwater Baseline Inspection for Offshore Structure ..................................................... 31
5.3.3 Intelligent Pigging (IP) Inspection ...................................................................................... 31
5.3.4 Underwater Baseline Inspection for Pipeline external ........................................................ 32
5.4 Anomaly Management (during Execute phase) ................................................... 32
5.5 Procedure Development ...................................................................................... 32
5.6 Competency Assurance ...................................................................................... 33
APPENDIX A: ASSET INTEGRITY FOR EXECUTE PHASE ACTIVITIES .................................. 34
APPENDIX B: ORGANIZATION CHART FOR O&M AND ASSET INTEGRITY DURING
EXECUTE PHASE ...................................................................................................................... 43

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LIST OF FIGURES

Figure 1.1: Block SK320 Location

Figure 1.2: Schematic of the Pegaga Development

Figure 3.1: Sub groups of asset integrity

Figure 3.2: The asset integrity in Execute Phase

Figure 3.4: The Road map for Asset Integrity requirement in Execute Phase

Figure 5.1: The generic risk based inspection process

Figure 5.2: The COMPANY 5 x 5 Risk Matrix

LIST OF TABLES

Table 3.1: Key dates for Asset Integrity Road Map

Table 4.1: Project Validation scope

Table 4.2: List of KPI according to CONTRACTOR’s Contract Quality Plan (CQP)

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1 INTRODUCTION

1.1 Project Background

MDC Oil and Gas (SK 320) Ltd (“COMPANY”) is the Operator of Block SK320 offshore
Sarawak, Malaysia as shown in Figure 1.1 under a production sharing contract and is
developing a number of gas field discoveries in this block. The largest of these, Pegaga,
is the focus of the development. The Pegaga field is in a water depth of about 108 m
and is in the vicinity of a range of existing infrastructures, as shown in Figure 1.2. The
gas and condensate will be exported to the Bintulu MLNG terminals.

1.2 Facility Description

The Pegaga Development consists of a manned Integrated Central Processing Platform
(ICPP). Dehydrated Gas and Condensate from Pegaga will be evacuated via a 38”
subsea pipeline to an existing 38” pipeline (PL-395) and onward to the E11R-B hub
platform. Tie-in to PL-395 is via a subsea Wye. The Pegaga gas will comingle with gases
from other sources at E11R-B and will be routed to MLNG Gas Metering Station 2
(GMS2). From E11R-B, the gas and condensate will travel to shore via the existing 36”
Trunkline 3 (PL-393) and Trunkline 4 (PL-394). The schematic of the Pegaga Facility is
shown in Figure 1.2. The design capacity for gas production and processing is 550
MMSFCD which will be produced from seven (7) wells, drilled from a Wellhead Deck.
The facilities for Pegaga ICPP are designed, fabricated, installed, commissioned and
handed over to COMPANY for this EPCIC scope as stated below:
• A main ICPP Process Deck with all hydrocarbon processing and utility systems.
• Living Quarters (LQ) integrated to ICPP, designed for seventy (70) personnel.
• An 8-legged ICPP Jacket.
• A ten (10) slot Wellhead deck with seven (7) working and provision for three (3)
future well slots installed at the same time as the jacket.
• 38” subsea pipeline from Pegaga to PL-395 pipeline subsea tie-in.
• Subsea Wye tie-in between new 38” pipeline from PEGAGA and existing 38” PL-
395.
• SSIV (Subsea Isolation Valve) Manifold at Pegaga ICPP.

North Luconia
Delta

SK320

Baram Delta

Central Luconia

Rim

Balingian

Tatau Province

Figure 1.1 Figure 1.2

Block SK320 Location Schematic of the Pegaga Development

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1.3 Purpose of Document

As a derivative of the Mubadala Petroleum Operations Management System and the sub-
set Asset Integrity Management Standard, the Project Asset Integrity requirements for
“EPCIC Execute phase” document has been used in providing the plan of the activities for
the elements required to ensure that all credible integrity threats with the potential to result
in Health, Safety, and Environmental (HSE) impact. Additionally, economic and
reputational aspects must also be covered, ie integrity threats which endanger equipment/
items (COMPANY’s assets) or affect production or reputation. Beyond that, in the project
phase, design Integrity must be verified and inspectability, operability and maintainability
shall be reviewed and validated.

1.4 Scope of Document

This document identifies the elements relevant to Asset Integrity requirements in “Execute
phase” and its activities for the preparation of handover to COMPANY’s Operations prior
to Start-up and Commissioning of the Pegaga facilities. CONTRACTOR scope covers the
Asset Integrity plan in “Execute phase” which addresses the Technical Integrity during
Detailed design engineering (DDE), Procurement, Construction, Transportation &
installation, Hook-up, testing and Commissioning.

In addition, this document will demonstrate that equipment/ items to be operated as

intended and that appropriate practices and procedures to sustain functional performance
have been addressed. The achievement of Technical Integrity therefore necessarily
requires that:

• Potential functional failures have been identified and assessed, and appropriate
inspection, maintenance and testing regimes are developed for their prevention and
/ or detection prior to start-up.
• Appropriate quality and competency management systems have been established
and applied and are subjected to on-going/ continuous reviews and audits.
• Asset “as-built” design, mechanical completion / acceptance, commissioning
records and safe operating limits have been accurately documented for reference
and handover to COMPANY’s Operations and Productions.

1.5 Reference

Reference Title

Exhibit 3.0 Scope of Work

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 Reference Title

Exhibit 7.0 List of Codes and Standards

Exhibit 14.0 Integrity Management Requirement

Exhibit 22 Regulatory Compliance Requirement

Project Asset Integrity Requirements

MPMY-AI-PLN-0002_2.0_IFU
(Execute Phase)

PGGA-PM-CEP-0001 Contract Execution Plan (CEP)

Baseline Data Collection Procedure for

PGCA-MT-REP-0002
Pressure Equipment

CO-GEN-OP-GN-STD-0001 MP's Operations Management System

CO-GEN-AI-PG-STD-0001 Asset Integrity Standard

CO-GEN-PF-HS-STD-0001 Safety Critical Element Standard

COMPANY Operational Risk Management

CO-GEN-HS-HS-STD-0004
Standard (ORMS)

PGGA-QM-PLN-0-001, Rev C.1 Contract Quality Plan (CQP)

PGGA-PM-PLN-0-008, Rev C.1 Regulatory Compliance Management Plan

PGGA-PM-PLN-0-004, Rev C.1 Risk and Opportunities Management Plan

PGGA-PM-PRC-0-006 CONTRACTOR Management of Change

Pressure System Baseline Inspection

PGGA-PM-PRC-12-001
Guideline

2 DEFINITIONS AND ABBREVIATIONS

2.1 Definitions

The following definitions shall apply throughout the procedure;

COMPANY : MDC Oil & Gas (SK320) Ltd

CONTRACTOR : Sapura Fabrication Sdn Bhd

WORK : Provision of Engineering, Procurement, Construction,

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 Installation and Commissioning (EPCIC)

SUBCONTRACTOR : Subcontractors employed by CONTRACTOR

Vendor : The party which supplies equipment, and materials

ordered by CONTRACTOR

Site : Site means the location (s) of the offshore facilities and
Pipelines

Worksite : Worksite means the SITE, all fabrication yards including

engineering offices outside the SITE, individually or
collectively, where any part of the WORK shall be
performed.

Shall : “shall” denotes a minimum requirement in order to

conform to the specification.

Should : “should” denotes a recommendation or that which is

advised but not required in order to conform to the
specification.
May : “may” indicates recommendations that are optional.

Will : “will” indicates something is going to happen or intention

to do it in the future.

As Low As : A level of risk that is acceptable and cannot be reduced

Reasonably further without incurring excessive costs which would be
Practicable (ALARP) disproportionate to the benefits gained.

Asset Integrity : The ability of an asset to perform its planned function

effectively and efficiently for its intended purposes
throughout its service life.

Technical Integrity : Technical Integrity is achieved through the completion of

auditing, inspection, testing, witnessing and examination
activities to ensure that the criteria set by the
Performance Standard (PS) of each SCEs are met.

Asset Integrity : Asset integrity management is the development,

Management (AIM) implementation and execution of a coordinated plan
together with managerial control and organizational
activities to ensure that the physical asset is performing

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 its intended function in a safe, effective and efficient
manner over its entire life cycle, in order to achieve the
organizational objectives.

Life Cycle Cost : Life Cycle Cost is defined as the total cost throughout its
life including planning, design, acquisition, support costs
and any other costs directly attributable to owning and
using the assets. In calculating the Life Cycle Cost
requirements, the cost associated with removal for onsite
and offsite calibration/ certification shall be taken into
account. It should also consider the cost associated with
Long Term Service Contracts (LTSA) if applicable and
rental/ membership fee of LTSA or spare unit (if
applicable).

Hazard : Has the potential to cause harm, including ill-health and

injury, damage to assets, products or the environment,
production losses or increased liabilities.

Hazard Identification HAZID systematically identifies conditions that could

Study (HAZID) : harm workers, the environment, or the asset. HAZID is
a precursor to a formal risk assessment.

Hazard and HAZOP is a qualitative, structured systematic examination

Operability study of a planned or existing production process (or part
(HAZOP) : thereof) in order to identify and evaluate problems that
may represent risks to personnel, equipment or the
environment, or prevent efficient operation.

Major Accident : MAH is defined as the following:

Hazards (MAH) (a) an event involving a fire, explosion, loss of well control
or the release of a dangerous substance causing, or with
a significant potential to cause, death or serious personal
injury to persons on the facilities or engaged in an activity
on or in connection with it;
(b) an event involving major damage to the structure of the
installation or plant affixed to it or any loss in the stability
of the installation causing, or with a significant potential to
cause, death or serious personal injury to persons on the
installation or engaged in an activity on or in connection
with;
(c) the failure of life support systems for diving operations
in connection with the installation, the detachment of a

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 diving bell or other subsea chamber used for such
operations;
(d) any other event arising from a work activity involving
death or serious personal injury to five or more persons on
the facilities or engaged in an activity on or in connection
with; or
(e) any major environmental incident resulting from any
event referred to in paragraph (a), (b) or (d) above.
Risk : The product of the consequence and likelihood
associated with hazardous event.

Risk Matrix : A table that graphically displays risk as the product of

Likelihood and Consequence. It is used as the basis for
qualitative risk determination.

Consequence : Adverse effect, harm, damage or other similar loss

arising from a specific event.

Equipment : An individual item that is part of a system, equipment is

comprised of an assemblage of Components.

Inspection : Activities performed to verify that materials, fabrication,

erection, examinations, testing, repairs etc conform to
applicable code and Standard, engineering, and/ or
owner’s written procedure requirements.

2.2 Abbreviations

AIM Asset Integrity Management

ALARP As Low As Reasonably Practicable
CA Certifying Authority
CAPEX Capital Expenditure
CDBM Corrosion Design Basis Memorandum
CML Condition Monitoring Location
CMP Corrosion Management Plan
CMS COMPANY CONTRACTOR Management Standard
CMMS Computerized Maintenance Management System
COF Consequence of Failure
CP Cathodic Protection
CRA Corrosion Risk Assessment
DDE Detailed Design Engineering
DBM Design Basis Memorandum
DOSH Department of Occupational Safety and Health
EDMS Electronic Document Management System

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EPCIC Engineering, Procurement, Construction, (Transportation &)
Installation and Commissioning
EERA Escape, Evacuation and Rescue Analysis
ESSA Emergency System Survivability Analysis
FEED Front End Engineering Design
FERA Fire and Explosion Risk Assessment
FMD Flooded Member Detection
GTG Gas Turbine Generator
H2S Hydrogen Sulfide
HAZID Hazard Identification
HAZOP Hazard Operability
HC Hydrocarbon
HFE Human Factor Engineering
HUC Hook up and Commissioning
ICPP Integrated Central Processing Platform
ICSS Integrated Control and Safety Systems
IP Intelligent Pigging
IPF Instrumented Protective Function
ITP Inspection Test Plan
IVB Independent Verification Body
KPI Key Performance Indicators
LCC Life Cycle Cost
LCCA Life Cycle Cost Analysis
MAH Major Accident Hazards
MDR Master Deliverable Register
MP Mubadala Petroleum
MOC Management of Change
MWS Marine Warranty Surveyor
NDT Non-destructive Testing
OEM Original Equipment Manufacturer
OMSB Ocean Might Sdn Bhd
OPEX Operation Expenditure
PC Procurement and Construction
PDMS Plant Design Management System
PFD Process Flow Diagram
PMT Project Management Team
POF Probability of Failure
P&ID Piping & Instrument Diagram
PS Performance Standard
QRA Quantitative Risk Analysis
RAM Reliability, Availability and Maintainability
RBI Risk Based Inspection
RCM Reliability-centered maintenance
RFQ Request for Quotation
RT Radiographic Testing
SCE Safety Critical Element
SFSB Sapura Fabrication Sdn Bhd
SGIA Smoke and Gas Ingress Analysis
SIL Safety Integrity Level
SSIV Subsea Isolation Valve
UTTG Ultrasonic Testing Thickness Gauging
T&I Transportation & Installation
TBA To be advised

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 TBC To be confirmed
TBD To be developed
TEG Triethylene Glycol
TPA Third Party Agency
WHD Wellhead Deck

3 ASSET INTEGRITY REQUIREMENTS FOR EXECUTE PHASE

3.1 CONTRACTOR Asset Integrity Scope for Execute Phase

Within the EPCIC phases of Pegaga Project scope, the term ‘integrity’ refers to the
‘Technical Integrity’ of an equipment/ items which being designed, procured,
fabricated, constructed, inspected, installed and commissioned in a manner that
validates design integrity and ensure that the objectives are being met prior to handover
to COMPANY. Technical Integrity is achieved through the completion of inspection,
testing, witnessing, auditing and examination activities to assure that the technical
criteria set for all equipment/ items shall be met as set by the Performance Standard
(PS) of each SCEs.

Asset Integrity for each project can be achieved when the risk of a failure occurring which
would endanger the safety of personnel, the natural environment or asset value has
been reduced to is ‘As Low As Reasonably Practicable’ (ALARP). It is derived from the
aggregation of three (3) discrete components/ phases of integrity management which
prevail through the successive phases of the asset development and operations lifecycle
as described in Figure 3.1 below;

1. Design Integrity (Inherent safety)

2. Technical Integrity (Engineered Safety)
3. Operational Integrity (OI) (Procedural Safety)

Figure 3.1: Sub-groups of Asset Integrity

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 CONTRACTOR’S
SCOPE

Figure 3.2: Asset integrity in Execute Phase

Asset Integrity Management (AIM) is a continuous process throughout the asset lifecycle.
In general there are five phases in an asset’s lifecycle including identify/ access, evaluate,
concept definition, execute, and operate as illustrated in Figure 3.2. Substantial emphasis on
design integrity has been made at the concept selection and concept definition phases to
establish asset integrity requirements. For Execute phase, the focus will be on Technical
Integrity. However the process will continue as the project progresses from Execute phase to
Operate phase and handed over to COMPANY's Operations. During Operate phase, the focus
is on Operational Integrity (OI) and the assets need to be maintained in order to sustain its
integrity.

The Execute phase is concerned with the realisation of the FEED and ensuring that Regulatory
requirements, COMPANY requirements and Codes & Standards will be applied throughout
the subsequent Detailed Design Engineering (DDE), Procurement, Construction,
Transportation & Installation (T&I), Hook-up and Commissioning (HUC).

The detailed CONTRACTOR deliverables are presented in Appendix A.

3.2 Asset Integrity Plan

Asset integrity (AI) plan for Execute phase has been developed for Pegaga Project to
ensure the process of handover to Operate phase meet its all technical requirements.
The AI plan requires the systematic and continuous monitoring of activities from detail
engineering, procurement, manufacturing, construction, testing, installation,
commissioning, operation, inspection and maintenance to meet asset integrity
objectives. This plan shall demonstrate that all the all credible integrity threats which
could result in HSE impact are proactively identified, assessed and effectively controlled
throughout the execution phase and shall involve COMPANY, CONTRACTOR,
SUBCONTRACTORS, Suppliers, Vendors or other personnel who are performing works
and involved in Pegaga Project.
The entire AI plan/ program is further divided to activities, which being executed by

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 CONTRACTOR and in collaboration with SUBCONTRACTORs. Each relevant activity
is further detailed in Appendix A of this document.

The timeline of the execution of the asset integrity program is further discussed in
Section 3.3.

3.3 Asset Integrity Road Map

Asset Integrity road map has been developed for Execute phase to ensure that key
elements of the Asset Integrity requirement is addressed and delivered in timely manner.
The Asset Integrity Road Map is presented in detail in Figure 3.4 below. For easy
reference, the key dates are presented in Table 3.1;

Expected to Expected to
No. ACTIVITIES
Start Complete
(Actual)
Safety Studies in Detailed Design
1.0 Apr-2018 Feb-2019
Engineering
Major Accident Hazard (MAH)
2.0 29-Jun-2018 23-Nov-2018
Identification
3.0 Bow-tie workshop 28-Aug-18 29-Aug-18
Design and Operational Safety Critical
4.0 Elements (SCE) and Performance 30-Nov-2018 Apr-2019
Standards (PS)
Revision of detail design CMP (WHD
5.0 02-Jun-2019 07-Aug-2019
& CPP)
5.1 Review & update CMP 02-Jun-2019 26-Jul-2019

Expected to Expected to
No. ACTIVITIES
Start Complete
(Actual)
5.2 Submission of draft CMP Review
26-Jul-2019 30-Jul-2019
report
5.3 Submission of final CMP Review
30-Jul-2019 07-Aug-2019
Report
Update Corrosion Management
6.0 02-Jun-2019 05-Aug-2019
Strategies & Procedures
Review & update strategies &
6.1 02-Jun-2019 02-Aug-2019
Procedures
6.2 Submission of comments 02-Aug-2019 05-Aug-2019
7.0 Conduct CRA for Pressure System, 02-Jun-2019 29-Nov-2019
Structures & Pipelines
7.1 CRA Pressure System 02-Jun-2019 10-Oct-2019
7.2 Conduct CRA for Structures As confirmed by MP, CRA for
Structures & Pipeline not required.
8.0
Key-Point Location (or Corrosion 02-Jun-2019 09-Jun-2020
Monitoring Location – CML)

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8.1
Define CMLs on Isometric WHD 02-Jun-2019 18-Oct-2019
8.2 Define CMLs on CPP
02-Jun-2019 15-May-2020
8.3 Define CMLs on Pressure Equipment
02-Jun-2019 22-May-2020
9.0 Baseline Inspection
02-Jun-2019 *03-Feb-2021
9.1 Baseline Inspection (UTTG) for WHD
02-Jun-2019 16-Mar-2020
9.2 Baseline Inspection (UTTG) for CPP
01-Jul-2020 *27-Mar-2021
10.0 Baseline Collection 13-Feb-2020 *27-Apr-2021

10.1 Collect and Populate WHD 13-Feb-2020 16-Mar-2020

10.2 Collect and Populate CPP 30-Jul-2020 *27-Apr-2021
Revisit Asset Register for CMMS
11.0 02-Sep-2020 16-Nov-2020
Synchronization
Revisit the 1st edition, Identify Gap and
11.1 02-Sep-2020 16-Mar-2020
Resolve as per CMMS requirement
Submission of Draft Asset Registration
11.2 02-Sep-2020 31-Mar-2020
Database & Hierarchy (Rev 2)
Submission of Final Asset Registration
11.3 30-Oct-2020 17-Aug-2020
Database & Hierarchy (Rev 2)
12.0 Risk-based Inspection Assessment
30-Sep-2019 16-Dec-2020
& Inspection Program
12.1 Asset Registration 13-Nov-2019 14-Feb-2020
12.2 RBI Assessment for Pressure System 03-Feb-2020 10-Sep-2020
12.3 RBI Assessment for Structures 11-Sep-2020 04-Nov-2020
12.4 RBI Assessment for Pipeline 11-Sep-2020 24-Dec-2019
13.0 Underwater Baseline Inspection –
June-2021 10-Oct-2021
Structures & Pipelines and IP
13.1 Underwater Baseline Inspection +
June-2021 June-2021
External Inspection for Pipeline- ROV
and CP
13.2 Compile Underwater Baseline
Inspection – Structures & Pipelines
*17-Aug-2021 *17-Sep-2021
into CMMS
13.2 Intelligent Pigging (IP) Inspection for
*01-Oct-2021 *10-Oct-2021
new 4km Pipeline internal
14.0 Produce Inspection programme for the
first 5 years of Production Operations
July-2020 Dec-2020
for Pressure Equipment, Pipeline and
Structures.
15.0 Procedure Development activities Apr-2019 Apr-2020
16.a DDE QA Audit No.1 13-Jun-2018

16.b DDE QA Audit No.2 15-Jan-2019

17.a Management Review No.1 Jan-2019

17.b Management Review No.2 Jul-2019

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17.c Management Review No.3 Jan-2020

17.d Management Review No.4 Jul-2020

17.e Management Review No.5 Jan-2021

Table 3.1: Key dates for Asset Integrity Road map (during Project execution)

Not Not
Required Required

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Page 18 of 44
 All Safety studies have been addressed during the DDE stage and completed on
February 2019 with the last workshop to be conducted is Design HSE Case
presentation. SCEs and PS planned to be conducted after the design HSE case
considering all the elements of technical integrity have been included. SCEs and PS is
envisaged to be completed before the start of Asset register development for RBI and
CMMS database preparation.

Two (2) DDE Audits is planned to be conducted as follows;

• 1st DDE Audit - before 90% PDMS Review for WHD
• 2nd DDE Audit - before 90% PDMS Review for CPP

The management reviews is planned to be held for every 6 monthly. Details can be
referred to Section 4.5.4.

The underwater baseline inspection to be carried out during T&I 2nd campaign which
is approximately in Early June 2021. Meanwhile IP will be carried during T&I campaign
which is scheduled on Early October 2021 (tentative).

4 ASSET INTEGRITY ACTIVITIES

4.1 Project Validation

To support the confirmation of Design Integrity during the detailed design engineering
(DDE), COMPANY has engaged an Independent Verification Body (IVB) (i.e Bureau
Veritas (BV)) who independently verified the detailed design engineering deliverables
performed by CONTRACTOR.

For the Execute phase, COMPANY and CONTRACTOR have engaged and employed
the independent bodies in validating the following scopes;

Independent
Phases Scope of work Engaged by
Bodies
To review and verify the
entire detailed design
engineering which has
been performed by
CONTRACTOR and
Independent
Detailed design issue a Certificate of
Verification Body COMPANY
engineering (DDE) Fitness for the design of
(IVB)
the facilities to confirm
the adequacy and
correctness according to
the required Codes &
Standards.
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 Phases Independent Scope of work Engaged by
Bodies
To review all aspects of
marine operations
associated with the load-
Transportation & Marine Warranty
out, transportation and COMPANY
Installation (T&I) Surveyor (MWS)
installation of the Pegaga
facilities.

Procurement, To verify the facilities are

Construction, built to Contract
Transportation & requirements and Codes
Certifying
Installation (T&I) and and Standards, starting CONTRACTOR
Authority (CA)
Hook- up and from Procurement until
commissioning Commissioning.
(HUC)
To certify the equipment
/ material to be procured
by the CONTRACTOR.
This Inspection Agency
will also supply the
Third Party specialist man-power to
Procurement Inspection inspect and monitor the CONTRACTOR
Agency (TPA) work executed by the
CONTRACTOR during
procurement, fabrication,
installation and
handover.

Table 1.1: Project Validation scope

4.2 Leadership and Accountability

CONTRACTOR is in collaboration with its SUBCONTRACTORs and with the clear

guidelines and leadership of COMPANY shall demonstrate its commitment towards
achieving the objective of ensuring the effective and efficient implementation of all
aspects of the AIM requirements during Execute phase. CONTRACTOR has defined the
individual responsibilities and accountabilities of relevant parties in Appendix A.

Part of CONTRACTOR’s commitment towards achieving the objectives of AIM is by

conducting the following;

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 a) Establishment KPIs, as presented in detailed in Section 4.5.1.
b) Include AIM as part of agenda during a six (6) monthly Management review as
well as during Project Quality Internal Audit (within CONTRACTOR EPCIC
disciplines), Project Quality External Audit (within CONTRACTOR’s
SUBCONTRACTORs, Vendors and Suppliers), COMPANY Audits and Project
Readiness Review Audits (i.e prior to load-out, start-up).
c) Include AIM as part of agenda during programme organized by COMPANY for
management site tours during Construction phase.

4.3 Laws and Regulations

Complying with Laws and Regulations as defined in Exhibit 22 Regulatory

Compliance Requirement and PPGUA 4.0 (Procedures & Guidelines for up-stream
activities, Manual is mandatory. CONTRACTOR shall ensure adherence to the
applicable Guidelines as set by COMPANY and elements of Health, Safety and
Environment (HSE) are embedded into the asset life cycle. To comply with laws &
regulations and approval from related regulatory authorities, CONTRACTOR has
established Regulatory Compliance Management Plan; Document No. PGGA-PM-
PLN-0-008. The plan includes the identification of Regulatory person/parties
involved throughout the execution of work and Regulatory Register which maps the
engagement plan and application requirement to be made with the respective
regulatory body.

4.4 Codes and Standards

COMPANY’s specifications, international codes, standards and recommended

practices (e.g ISO, API, ASME, IEC, etc) and where applicable, Petronas’s
specifications have been used and referred during the entire Project phase. Any
deviations are only allowed on case by case basis and can only be implemented
after receiving written approval from the COMPANY. Deviations are further
discussed in Section 4.6.

4.5 Performance Evaluation

4.5.1 Key Performance Indicators (KPI)

Project KPI has been established in accordance with the Scope of Work (Exhibit
3.0) and can be referred to Contract Quality Plan (CQP), PGGA-QM-PLN-0-001,
Clause 5.2, Appendix 3. The respective Discipline Managers are responsible to
report the KPI as per the frequency defined in the CQP.
The Project QA/QC Manager is responsible in collating all relevant data from
process owners and analyse for performance monitoring. The KPI and analysis
report shall be presented to the CONTRACTOR’s Project Director and subsequently
issued to the COMPANY Management.

Page 19 of 43
Page 20 of 43
Table 1.2: List of KPI according to Contract Quality Plan (CQP)

Page 21 of 43
4.5.2 Implementation of Quality Assurance/ Quality Control (QA/QC)

It is a CONTRACTOR’s responsibility for the implementation of Quality assurance and

Quality control (QA/QC) throughout the Pegaga project. A well-established methodology
is administered under the ISO 9001:2015 QMS standard. Both COMPANY and
CONTRACTOR will administer their own independent QA/QC programs towards
providing confidence that asset integrity processes will be progressively developed and
implemented during the Execute phase and provide connectivity between Project and
handover to COMPANY Operations. The QA/QC programmes are discussed within
Section 4.5.3.

4.5.3 Inspections and Audits

4.5.3.1 Inspections

For Execute phase, all fabrication, inspection, testing and acceptance criteria shall be
conducted in strict accordance with relevant Regulatory and COMPANY requirements
and National / International Codes & Standards.
Specific requirements are identified in CONTRACTOR’s Inspection & Test Plans
(ITPs), Source Inspection Plan, Regulatory Inspection plan and the application of the
stated requirements shall be subject to routine surveillance inspections and audits by
the COMPANY throughout the Execute phase.

4.5.3.2 Audits

CONTRACTOR with the participation of COMPANY will conduct a series of project audits
and reviews during the course of Work. These audits and reviews will be conducted
during Detailed Engineering, Construction, Installation and prior start up
(Commissioning) as required by COMPANY. As mentioned in Section 4.2 above, audits
for AI will be included as part of agenda during Project Quality Internal Audit, Project
Quality External Audit, COMPANY Audits and Project Readiness Review Audits. Details
of the overall audit plan can be referred to Project Audit Schedule as established for this
Pegaga project.

4.5.4 Management Review

As a commitment towards achieving the objective of ensuring the effective and efficient
implementation of all aspects of the AIM requirements during Execute phase,
CONTRACTOR will include the AIM as part of agenda during a six (6) monthly
Management. Details of the planned date can be referred to Table 3.1 above.

Page 22 of 43
 The following inputs will be included as a minimum to the Management Review
agenda;
• Status of KPI relevance to the AI function
• Status of Action arising from previous management reviews.
• Status of planned COMPANY and CONTRACTOR audits and review of any
previously identified non-conformances along with their current status.
• Lesson learned and actions taken to prevent recurrence
• Opportunities for improvement in COMPANY’s Asset Integrity programme.
• Modifications to the Internal Audit/ External Audit Schedule to reflect recent
audit findings

Review meetings shall be involved with COMPANY selected Project Management

personnel and subsequent Actions resulting to these reviews shall be recorded along
with identifying the assigned Actionee and an agreed date for close-out.

4.6 Management of Change/ Deviations

During the Execute phase, any changes initiated by COMPANY and/or proposed by
CONTRACTOR shall be managed using the CONTRACTOR Management of Change
(MOC) Procedure, PGGA-PM-PRC-0-006 with cross-reference to COMPANY
Management of Change (MOC) Procedure, MY-GEN-PF-PM-PRC-0008-R2 and Exhibit
26: Administrative Procedure, clause 3.1 Management of Change.

Management of Change (MOC) is a key sub-process of the overall Integrity Management

system. COMPANY has introduced a Management of Change process to ensure that all
changes are systematically implemented such that technical integrity and HSSE
implications are adequately assessed and managed, relevant documentation is
completed and the correct level of authority is employed in approval of all changes prior
to the implementations.

All changes in the project, such as management being applicable to contract changes,
design concession, field design changes, process changes, technical queries, in people,
equipment and working procedures shall be recorded in proper planning and controlling
to avoid any HSSE and QA/QC consequences. The Change control procedures
(Technical Query Procedure, Concession Request Procedure, and Variation Order
Procedure) address the requirements of various changes.

As a minimum, the reasons for the change may include the following reasons;

• An external event (i.e a change in Regulatory requirements)

• An error or omission during the Scope of Work definition
• A value adding change (i.e additional works resulting from Value Engineering
workshop)

Page 23 of 43
 • A change in COMPANY business strategy
• A design aspect with the potential to adversely impact upon the Technical
Integrity of the facilities
• A change in technology during Project execution
• Establishment of better engineering or construction solutions during the course of
Project execution.

4.7 Risk Management

The CONTRACTOR’s Project Risk Management has been developed to fulfil the
requirement of risk management which has been set in COMPANY’s Operational Risk
Management Standard, Document No. CO-GEN-HS-STD-0004. COMPANY’s
Operational Risk Management Standard has been introduced to support the
Operational Management System to ensure that risks arising from COMPANY’s
activities are continuously assessed throughout the business cycle and that
appropriate action plans are implemented to prevent, or reduce risks to an acceptable
level. Risk Management which includes inspection and maintenance planning, is one
of the requirements to be performed and not a one-time activity but a continuous
process where information and data from the inspection/maintenance/monitoring
activities performed during Execute phase are provided to COMPANY’s planning and
strategy development for maintaining its assets and ensure the following objectives
have been met;

• All risks potentially impacting the project are identified, assessed and pro-
actively are managed.
• A clear and concise process for documenting risks and their controls are
provided.
• Project effectiveness in managing the risks is increased.
• Project management to make risk-based decisions supported by qualitative and
quantitative risk & opportunities analyses is managed.

CONTRACTOR’s Project Risk Management (refer to Risk and Opportunities

Management Plan, Doc No PGGA-PM-PLN-0-004) sets out the processes and
activities that will be applied to the project to manage risk. The plan describes the
methodology for identifying, recording, analysing, quantifying, managing and tracking
risks & opportunities that occur during the project. It assigns specific responsibilities
for the management of risks and prescribes the documenting, monitoring and reporting
processes to be followed.

The core components of the risk management approach will be well monitored and will
be administered during project execution with reference and guidelines to COMPANY’s
Operational Risk Management Standard, COMPANY’s 5x5 Risk Matrix (Figure 5.2) and
CONTRACTOR’s Risk and Opportunities Management Plan (PGGA-PM-PLN-0- 004).

Page 24 of 43
4.8 Barriers for Safety in design

A barrier is described as a functional grouping of safeguards and controls selected to

prevent the realisation of a hazard. Each barrier typically includes a combination of
equipment, process and people. The selected combination of these ensures the barrier
is suitable, sufficient and available to deliver its expected risk reduction.
CONTRACTOR defined the barriers in safety design into two categories which are
Design Safety Critical Elements (SCEs) and Performance Standard (PS) and selected
Safety studies which shall be developed or further refined during detailed engineering.
The deliverables for barriers for Safety in design can be referred in Appendix A.

4.8.1 Safety Studies during Detailed Design Engineering (DDE)

Safety studies addressed and conducted during detailed engineering is very important
to the development of Asset Integrity. Safety studies are the earliest and initial qualitative
risk assessment to be carried out for the facilities to identify any risks to the systems,
subsystems and components including subsea facilities. The importance of safety
studies is very significant to demonstrate to COMPANY that its assets are safe to be
operated and maintained. It is also important to reduce risks for Production or service
losses from equipment/ assets failure which could contribute to loss of life or impact to
the environment.

One of the important activities in Safety studies is the Hazard Identification (HAZID). The
hazard identification process identified that loss of containment and/or loss of pressure
systems, piping, structural integrity as well as pipeline could occur as the result to Internal
& external corrosion, external mechanical damage etc. HAZID study performed during
DDE is significant since it relies on knowledgeable individuals/ personnel contributing
their experience and judgments to the process including the input gained from
COMPANY Operation.

It is usually desirable to list all the potential failure mechanisms that could occur and
subsequently screen out those which are considered unlikely or otherwise inappropriate
of further consideration. Applying a “what if…” approach increases the potential for
capturing all the potential failure mechanisms. This approach to hazard identification
(HAZID) can be further formalized using techniques such as the HAZOP (Hazard and
Operability Study) where guidewords are used to structure the discussions of the hazard
identification team. All the hazards assessed should be recorded so that they too can be
reviewed in the light of the in data and operational experience.

The other selected Safety studies are also important to be developed or further refined
by the CONTRACTOR during Execute phase. These Safety Studies are summarized as
follows; (Note: The list of Safety studies below is not exhaustive).

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 • Smoke and Gas Ingress Analysis (SGIA)
• Fire and Gas Mapping Study
• SIL Verification Study
• Noise Study
• HAZID for Construction, Installation, Hook-up and Pre-Commissioning
• Safety Critical Element and Performance Standard
• Human Factor Engineering
• Vibration Study (Acoustic & Flow Induced) forms part of the Engineering work-
scope

The combined output of these Safety Studies will be incorporated into the design and
culminate in Operations HSE Case being developed by CONTRACTOR for handover to
the COMPANY Production Operations Group prior to start-up of the facilities.

4.8.2 Development of Safety Critical Elements (SCE) and PS

Technical Integrity is Management of hardware risk barriers to safeguard the design

integrity in order that it can work within the operational barriers. Technical Integrity
ensures that equipment is properly designed, fabricated, installed and maintained in
accordance with recognised standards and codes, and that it fulfils its design intent and
remains fit for purpose until removed from operation.

Technical Integrity is ensured by the existence and performance of a series of integrity

barriers (Safety Critical Elements (SCE)), which prevent or minimise the consequences
of a Major Accident Hazard (MAH). There are eight (8) SCE Hardware Barriers as
detailed below:

• Structural Integrity;
• Process Containment;
• Ignition Control;
• Detection Systems;
• Protection Systems;
• Shutdown Systems;
• Emergency Response;
• Life Saving.

The role of SCEs is to prevent or limit the escalation and/or consequences of a MAH.
For each SCE identified at the asset, Performance Standards (PS) are developed which
in turn inform the maintenance, testing and inspection requirements to ensure the
integrity of the system. Technical Integrity on a Pegaga is delivered when PS for SCEs
have been produced and implemented.

Page 26 of 43
4.8.2.1 Safety Critical Elements (SCE)

Any structure, equipment, system or component part whose failure could cause or
contribute substantially to a Major Accident Hazards (MAH) is considered as SCE. SCEs
also include those items that are crucial to the prevention, control or mitigation of MAH.

SCEs consisted primarily of hardware equipment (e.g. vessels, instrumentation etc.) but
can also constitute activities (e.g. procedures, tasks) that influence the prevention or
recovery from MAH.
Narrowing the definition of a SCE in the context of asset integrity is deliberate and does
not imply that all other high asset/reputation risk or medium to low risks are in any way
neglected.

4.8.2.2 Performance Standards (PS)

Development of Performance Standards (PS) is a critical activity to ensure technical

integrity requirement is being met. Performance Standards (PS) for barriers are typically
described in terms of functionality, availability, reliability, survivability and interaction.
Performance standards thus determine equipment design specifications (original
suitability) and also set requirements for maintenance and testing throughout the asset
lifecycle (ongoing suitability). It is helpful to consider a range of possible performance
standards for each component- typically based on recognized design standards – and
then optimize the overall barrier to give the most cost effective risk reduction. Such
barrier optimization needs input from Operations and often risk assessment specialist to
ensure that all relevant factors are considered. There can also be performance standard
optimization between barriers. Once performance standards are defined, assurance
processes should be put in place to confirm that barriers remain fit for the purpose and
as per requirement. Typically, this will require initial equipment type-testing and/or barrier
commissioning performance tests, operational controls and limits, maintenance,
inspection and testing plans; performance records for both individual equipment.

4.9 Life Cycle Cost (LCC) in Procurement process for Type 1 Equipment

Life Cycle Cost is defined as the total cost throughout its life including planning, design,
acquisition, support costs and any other costs directly attributable to owning and using
the assets. For procurement exercise of Type 1, LCC analysis shall be carried out as
cross-reference to Exhibit 3.0, Clause 7.9.1, Commercial Bid Evaluation – Equipment
and Material type 1. In calculating the LCC requirements, the cost associated with
removal for onsite and offsite calibration/ certification shall be taken into account. It
should also consider the cost associated with Long Term Service Contracts (LTSA) if
applicable and rental/ membership fee of LTSA or spare unit (if applicable).

Page 27 of 43
 For each equipment and materials package with a Equipment and Material Type 1,
RFA report will be prepared accordingly. Each report will cover the following subjects;
• Commercial summary analysis (spreadsheet presentation) of each Bidder who
has been technically approved by COMPANY.
• Incorporate all Life Cycle Costing analyses as above.
• Based on technical compliance and COMPANY acceptance, CONTRACTOR will
proceed with placement of Purchase Order in favour of technically acceptable and
commercially lowest Life Cycle Cost (LCC). The principle of LCC analysis in
Contract Bid Evaluation (CBE) and Recommendation of Award shall be applied
for the equipment listed below;

❖ TEG Regeneration & Gas Dehydration package

❖ Gas Turbine Generator (GTG)
❖ Firewater Pump package
❖ Submersible pump
❖ Pedestal cranes
❖ SSIV skid
❖ Subsea wye
❖ Shell & tube heat exchanger
❖ Pressure vessels
❖ ICSS
❖ Gas metering
❖ Condensate metering
❖ Wet Gas Flow Meter (WGFM)
❖ Aviation fuel package
❖ Analyzer (H2S, CO2, Moisture, Mercury, Water in Condensate, HC in Nitrogen).

5 CORROSION, ASSET INTEGRITY AND INSPECTIONS PROGRAMME

5.1 Corrosion Risk Assessment (CRA)

Corrosion is a major deterioration phenomenon affecting process equipment, piping,

structures and pipelines during Operational phase. During detailed design engineering,
materials of construction have been carefully studied, keeping corrosion resistance as
one of major decision factors. The threats from all credible failure mechanisms that may
be experienced on static pressure systems (i.e piping and pressure vessels) during
Operational phase have been defined and registered in Pegaga Corrosion Management
Plan (CMP). To monitor both expected and unexpected corrosion, inspection programs
are planned as part of normal plant activities. In achieving these objectives, the corrosion
risk analysis is very important in classifying the relative

Page 28 of 43
 severity of corrosion risk. It is important to note that CRA mainly contributes to the PoF
assessment in RBI analysis.

Figure 5.1: The generic risk based inspection process

5.2 Risk-Based Assessment and Inspection Programme

RBI methodology will be used to manage the overall risk of a platform/ facilities by
focusing inspection efforts on the process equipment with the highest risk. RBI will
identify and manage the risks associated with the integrity of pressure systems,
structures and pipeline in order to reduce them down to an ALARP (as low as reasonably
practicable) level or mitigate them completely. RBI provides the basis for making
informed decisions on inspection frequency, the extent of inspection, and the most
suitable type of NDT required.

The RBI assessment will be conducted using COMPANY's risk matrix, as presented in
Figure 5.2 to develop an effective inspection plan. Inspection planning is a systematic
process that details out the inspection strategy, frequency, scope and coverage
according to the identified damage mechanisms. Both the probability of failure and the
consequence of failure (COF) should be evaluated by considering all credible damage
mechanisms that could affect the facilities or equipment. In addition, failure scenarios
based on each credible damage mechanism should be developed and considered

Page 29 of 43
 Figure 5.2: The COMPANY 5 x 5 Risk Matrix

By using the above Risk Matrix, the final Risk Ranking (the results of the Criticality Analysis) is
obtained by considering the Likelihood rating (on the X-axis) and the Consequence rating (Y-axis)
of the Risk Matrix to determine the risk. If this risk is unacceptable, then other mitigation or
improvement may be required to supplement the inspection plan to reduce the risk. When properly
implemented, risk-based inspection is highly effective in maintaining asset integrity compared to
conventional Inspection programmes.

5.3 Inspection Requirements/ Baseline Inspection Requirements

In general, the objective of inspection strategy is to address all credible failure modes, with the
scope and level of detail determined by the risk rating. In most circumstances this will result in a
limited range of inspection strategies, dependent upon equipment type, deterioration mode and
expected rate (time dependent mechanisms, e.g. general corrosion) or initiation conditions
(stochastic mechanisms, e.g. stress corrosion cracking). A separate inspection procedure will be
established to determine the scope, extent of inspection, technique/ methodology and formatting
report.

5.3.1 Baseline Inspection for Pressure Equipment

Baseline inspection for Pressure Equipment shall be performed once CMLs identification has been
defined. CMLs for Pressure Equipment are designated locations on pressure vessels and piping
where thickness measurements inspections are conducted to monitor the presence and rate of
damage and corrosion. Detailed of Baseline Inspection requirements can be referred to PGGA-
PM-PRC-12-001 Pressure System Baseline Inspection Guidelines.

Page 30 of 43
5.3.2 Underwater Baseline Inspection for Offshore Structure

As part of baseline inspection requirement, underwater baseline inspection after the

jacket and topside installation will be carried out. Underwater baseline inspection is
planned to be carried out for Offshore structure in June 2021, which is during T&I 2nd
Campaign (after completion of floatover operation).

The scope of the Underwater baseline installation with reference to CIMG Rev.3B
shall include the followings:

• Visual assessment of the structure including appurtenances.

• FMD on all primary members and NDT on selected key structural members
and nodes (if applicable).
• Verify overall configurations of structural members against As-Built Drawings
• Check for damage, corrosion, anomalies, flooded member testing, anode
depletion, scour, debris, marine growth and condition of riser clamps.
• Assessment of coating deterioration on entire surface to determine need for
touch up painting or total re-coat.
• Cathodic protection (CP) reading and sacrificial anode condition including
attachments.
• Electrical continuity check for all structure intended to be protected by CP to
check for any shielding or deficiency.
• Update in COMPANY’s Risk Based Inspection (RBI) software on the survey
findings
• Specialist engineer and specialized marine spread will be mobilized (e.g.
Support Vessel), if required in order to perform the work.

5.3.3 Intelligent Pigging (IP) Inspection

As part of inspection requirement, the IP will be carried out for the 4 Km Pipeline
internal. CONTRACTOR plans to perform the IP for the new 4 Km Pipeline in Early
October 2021 after successfully getting Provisional Acceptance (PA) Certificate which
is scheduled on 30-Sep-2021 (based on Schedule C6).

Intelligent Pigging (IP) is an inspection technique whereby an inspection probe, often

referred to as a smart pig, is propelled through a pipeline while gathering important
data, such as the presence and location of corrosion or other irregularities on the inner
walls of the pipe.

Smart/ intelligent pigs are capable of performing advanced inspection activities as

they travel along the pipe, in addition to just cleaning it. Smart pigs use NDT
techniques such as ultrasonic testing (UT) and magnetic flux leakage (MFL) testing to
inspect for erosion corrosion, metal loss, pitting, weld anomalies, and hydrogen
induced cracking, among others. They are also able to gather data on the pipeline's
diameter, curvature, bends, and temperature.

Page 31 of 43
5.3.4 Underwater Baseline Inspection for Pipeline external

Underwater Baseline Inspection for pipeline external will be carried out using ROV
and CP inspection. Baseline data will be uploaded later in COMPANY's Asset Integrity
System. This will also include verification of anode spacing in accordance to pipeline
GA/ anode distribution diagram.

5.4 Anomaly Management (during Execute phase)

Anomaly management during Execute Phase involves the identification, reporting,

analysis and monitoring of defects which require future inspection and assessment.
These processes, for instance is a result of the manufacturing/ fabrication activities
such as weld repairs etc.

Any anomalies found during baseline inspection will be recorded and reported
immediately to COMPANY and subsequent repairs shall only be executed in strict
accordance with approved procedures.

The anomaly management will also reminds of monitoring requirements and offers a
simple interface for inspection and integrity teams to enter and analyse data.
Depending on the nature of the reported anomaly and type of component requiring
repair, COMPANY have reserve the right to increase the inspection activities on
similar components to ensure no inherent deficiency in the manufacturing and
fabrication process.

5.5 Procedure Development

During the Operations phase, the maintenance and inspection regime will be
supported by procedures to manage these activities. In this respect, additional
COMPANY procedures shall be developed during Execute phase in conjunction with
Production Operations to reflect industry-wide lesson learned from historical integrity
failures on operational facilities.

The development of procedures involves identifying need, gathering information,

drafting, consulting, review and approving of procedures.

The following steps summarise the key stages involved in developing the procedures;
1. Identify the needs based on COMPANY’s Operation requirement
2. Identify the responsible parties
3. Gathering information
4. Draft the procedures
5. Consult/ review with COMPANY’s Operation Team
6. Finalize and getting approval
7. Submission to COMPANY

Further details can be referred to Exhibit 14 Section 6.8.3, Project Asset Integrity
Requirements (Execute phase).

Page 32 of 43
5.6 Competency Assurance (during Execute phase)

All CONTRACTOR, its SUBCONTRACTOR and VENDOR personnel provided to

undertake discipline-based activities shall only be allocated to tasks for which they are
suitably trained, qualified and competent. The CONTRACTOR, its
SUBCONTRACTOR and VENDOR records shall include, at a minimum the following
elements;

a) A list of all inspection and testing personnel shall be prepared by the

CONTRACTOR, its SUBCONTRACTOR and VENDOR to show the qualifications
held and expiry dates, and the list shall be updated to reflect personnel changes
as the works progress.
b) All inspection and testing personnel shall be qualified to a recognised National or
International Standard and the CONTRACTOR, its SUBCONTRACTOR and
VENDOR shall hold original certification for these personnel for the duration of
their work activities.
c) Original certificates shall be retained in a secure central location that allows for
ready retrieval as required.
d) No CONTRACTOR, its SUBCONTRACTOR and VENDOR’s personnel shall
undertake any work after their certificate expiry date.

All inspection and testing personnel certification shall be subject to continuous review
by the COMPANY.

Page 33 of 43
APPENDIX A: ASSET INTEGRITY FOR EXECUTE PHASE ACTIVITIES

The Asset Integrity for Execute Phase Activities addresses key processes, activities and resources relevant to the contract.
REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES

1.0 Data Management Integrity for Execute Phase

1.1 Establish Documentation Integrity (i.e Identification, Controls etc.)

Refer to CONTRACTOR Contract Quality Plan (CQP), Document No. PGGA-QM-PLN-0-001, Rev.C1- AFC, Section 4.0 Data and Document Control ISO 9001:2015,
Clause 7.5

2.0 Project Validation

Refer to CONTRACTOR Contract Quality Plan (CQP), Document No. PGGA-QM-PLN-0-001, Rev.C1- AFC, Section 13.0 Independent Review of Design, Fabrication
and Installation (ISO 9001:2015, Clause 8.4)

3.0 Project Performance Requirement for Execute Phase

3.1 Quality Assurance

Refer to CONTRACTOR Contract Quality Plan (CQP), Document No. PGGA-QM-PLN-0-001, Rev.C1- AFC, Section 5.0 Quality Management (ISO 9001:2015 Clause
4.0,8.0,9.0.10.0)

3.2 Inspection Requirements (Quality Control)

Refer to CONTRACTOR Contract Quality Plan (CQP), Document No. PGGA-QM-PLN-0-001, Rev.C1- AFC, Section 5.0 Quality Management (ISO 9001:2015 Clause
4.0,8.0,9.0.10.0)
4.0 Interface Management & Regulatory Compliance

Refer to CONTRACTOR Contract Quality Plan (CQP), Document No. PGGA-QM-PLN-0-001, Rev.C1- AFC, Section 3.0 Interface Management& Regulatory
Compliance (ISO 9001:2015 Clause 8.0)

Page 34 of 43
 REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES

5.0 Safety Barriers in Execute Phase

5.1 HSE Case, Safety Critical Element (SCE) and Performance Standards (PS)
Major Accident Event
Contract
(MAE) Report
Specification and
PGCA-SA-REP-1-025
• Establish the Major Accident Hazard Scope of Work
(MAH) Identification Section B Exhibit
• Carry out a QRA (Quantitative Risk QRA (Quantitative Risk 3.0
PMTs Assessment)
Assessment) and Fire and Explosion PRW Project
PGCA-SA-REP-1-059
Risk Assessment (FERA). Execution Plan
• SCE Identification Development PGGA-PM-PEP-
Project SCE Identification and
1-001
Development of HSE Case, SCE and • Bow-Tie Assessment Engineering Register
5.1.1 PGCA-SA-REP-1-026
PS. • Performance Standard Development Manager PRW Engineering
• Performance Criteria assignment for Quality
Bow-Tie Assessment Management Plan
SCE/HSE items
• Assurance and verification activities Technical Safety PGGA-QA-PQP-
Subcontractor Safety Critical Element
ensures that SCE meet their PS (SCE) and 1-001
• Safety Critical Element (SCE) and Performance Standards MDR
Performance Standards Report Report

Design HSE Case

Operational HSE Case
5.2 Safety Studies
HAZID Study & Report
PMTs for WHD and CPP Contract
Specification and
Safety studies to demonstrate that • Establish and perform or refine from Scope of Work
HAZOP Study & Report
5.2.1 Pegaga assets are safe to be FEED all relevant Safety studies to Section B Exhibit
Project for WHD and CPP
operated and maintained. address all Safety requirements 3.0
Engineering
Manager IPF Classification & SIL Exhibit 5
Verification Study &

Page 35 of 43
 REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES

Helideck Turbulence
Study

Fire & Gas Mapping

Study

Noise Study

Vibration Study
(Acoustic & Flow
Induced)

Reliability, Availability
and Maintainability
(RAM) study

Passive Fire Protection

(Vessel Rupture Study)

Passive Fire Protection

(Primary Steel
Structural Collapse
Study)

HAZID (Construction,
Installation, Hook-up
and Pre-
Commissioning)
6.0 Design Control & Review in Detailed Design Engineering

Refer to CONTRACTOR Contract Quality Plan (CQP), Document No. PGGA-QM-PLN-0-001, Rev.C1- AFC, Section 6.0 Design Control & Review (ISO 9001:2015
Clause 8.3)

7.0 Procurement and Sub-Contracting

Page 36 of 43
 REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES

Each Vendor
• Prepare a Life-cycle cost analysis Package for Type
(LCCA) to determine the most cost- I Equipment
Contract
effective option among different Specification and
competing alternatives to purchase, Supply Chain
Manager, Life Cycle Cost Analysis Scope of Work
7.1 Life Cycle Cost for Type 1 Equipment own, operate, maintain and, finally, Section B Exhibit
(LCCA)
dispose of an object or process, when Procurement 3.0
each is equally appropriate to be Manager
implemented on technical grounds.
Sub-Contract
Manager

Buyer

For Source Inspection, refer to CONTRACTOR Contract Quality Plan (CQP), Document No. PGGA-QM-PLN-0-001, Section 7.0 Procurement and Sub-Contracting
(ISO 9001 : 2015 Clause 8.2.3, 8.4)

8.0 Corrosion & Integrity Management Program

• Review, update and revise the Contract

Corrosion Design Basis Memorandum PMT Specification and
Topside Corrosion
(CDBM) Scope of Work
Design Basis
• Review, update and revise the Topside AI Engineer/ Focal Section B Exhibit
Memorandum (CDBM)
point 3.0
Material Selection Report and Corrosion
Development of Corrosion Risk Management Plan (CMP) Exhibit 14.0
8.1 CMP
Assessment (CRA) • Conduct Corrosion Risk Assessment Baseline Data
Interface Manager
(CRA) for Pressure Systems, Piping, Collection
Structures and Pipeline CRA Report (including Procedure
Project QA/QC
• Identify corrosion loops / circuits and Manager IOWs) PGCA-MT-REP-
mark-up on As-Built P&IDs. 0002
• Identify Integrity Operating Windows AI Subcontractor
Mark-up Corrosion

Page 37 of 43
 REF RESPONSIBLE CONTROLLING
. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
NO. PARTIES

(IOWs). Loops / Circuits on As- API 581 vr 2016

Built P&ID API RP 571
API RP 584
Baseline Data
Collection Procedure
Anomaly Management
• Develop Baseline Data AI Subcontractor Procedure
8.2 Procedure Development Collection Procedure Exhibit 14.0
Subsea Baseline
Inspection Procedure
Intelligent Pigging
Procedure
• Establish asset register for RBI readings in Contract
RBI programme spreadsheets Specification and
Development of RBI Programme for PMT
Pressure Equipment and Piping • Identify Condition Monitoring Scope of Work
Location (CML) on Issued for Section B Exhibit
AI Engineer/ Focal Asset register in
Construction Isometrics. 3.0
point spreadsheet and
8.3 Development of RBI Programme for • Compile baseline readings in uploaded in
Pipeline and Structures Excel spreadsheet format Project QA/QC COMPANY's asset Exhibit 14.0
• Transfer baseline readings electronically Manager integrity system
to a COMPANY selected Asset Integrity
AI Subcontractor API 581 vr 2016
system.
RBI report (inclusive of
• Perform Risk-based Inspection (RBI) RBI programme for first

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 REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES

programme appropriate for the first 5 5 years) CRA report

years of Production Operations API RP 572
• Run the RBI software to deliver an initial TMLs mark-up on API RP 574
inspection programme for the facilities. Isometrics and GA API RP 583
• Upload the inspection schedule in drawings
CMMS
Baseline data in
spreadsheet and
uploaded in
COMPANY's asset
integrity system

Inspection schedule in
spreadsheet and
uploaded in
COMPANY's AI System
and CMMS
• Add baseline readings to Inspection
drawings (i.e. wall thickness reading at PMT
each unique location).
• Compile baseline readings in Excel AI Engineer/ Focal Baseline readings in
spreadsheet format point spreadsheets
Baseline Data
• Collect baseline wall thickness readings
Project QA/QC Collection
Baseline inspection for Pressure at the identified key-point locations Procedure
8.4 Manager Baseline Inspection
Equipment and Piping using CONTRACTOR inspection
Reports PGCA-MT-REP-
personnel. Inspection Anomaly Reports 0002
• Add baseline readings to Inspection SUBCONTRACT
drawings (i.e. wall thickness reading at OR
each unique location).
AI Subcontractor

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 REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES
Contract
Specification and
Scope of Work
• Visual assessment of the entire Section B Exhibit
structure including appurtenances. 3.0
• FMD on all primary members and Non-
Destructive Test on selected key PMTs
Post installation Exhibit 14.0
structural members and nodes
• Verify overall configurations of structural AI Engineer/ Focal baseline survey report
members against As-Built Drawings point Project
• Check for damage, corrosion, Baseline inspection Transportation &
Interface Manager Installation
anomalies, flooded member testing, multimedia (recordings,
photos, videos, etc) Requirements
anode depletion, scour, debris, marine Project QA/QC
Post Installation Baseline Survey for (MPMY-PM-PRC-
8.5 growth and condition of riser clamps. Manager
Offshore Structure 0008)
• Assessment of coating deterioration on Anomaly reports
entire surface to determine need for T&I Manager
touch up painting or total re-coat. Post Installation
Post Installation Baseline data compiled Baseline Survey
• Cathodic protection reading and Baseline Survey in spreadheets and Procedure
sacrificial anode condition including Subcontractor uploaded in Asset
attachments. Integrity System
• Update in COMPANY’s Risk Based AI Subcontractor Anomaly
Inspection software on the survey Management
findings. Procedure
API RP 2A
API RP 2SIM

PMTs
• ROV inspection of full pipeline length RBI readings in Contract
spreadsheets Specification and
Post installation survey for the • CP survey AI Engineer/ Focal
8.6 Scope of Work
pipeline • IP baseline survey point
Section B Exhibit
Interface Manager 3.0

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REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES
ROV inspection report
Project QA/QC CP survey report Exhibit 14.0
Manager
IP baseline survey
T&I Manager report Project
Pipeline RBI report Transportation &
Post installation Installation
Uploaded baseline data
survey of the Requirements
in COMPANY's Asset
pipeline
Integrity System (MPMY-PM-PRC-
Subcontractor
Uploaded RBI 0008)
AI Subcontractor programme for first 5
years in CMMS and AI Pipeline post-
IP Subcontractor System installation
surveys
procedures

IP Procedure

DNVGL-RP-F116
API RP 1160

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 REF. RESPONSIBLE CONTROLLING
NO. PROCESS (ES) KEY ACTIVITIES DELIVERABLE (S) DOCUMENT (S)
PARTIES
Contract
Specification and
• Launch IP from topside Pegaga Scope of Work
• Perform survey of internal Section B Exhibit
inspection for the 38-inch 3.0
Pegaga pipeline
• Subject to type of IP being used, Project QA/QC IP baseline survey Exhibit 14.0
the IP can either be retrieved Manager report
back to Pegaga or retrieved at
E11R-B T&I Manager Pipeline RBI report
• Process the data obtained from Project
launched IP AI Subcontractor
Uploaded baseline data Transportation &
in COMPANY's Asset Installation
IP Subcontractor
Integrity System Requirements
Intelligent Pigging (IP) Inspection for (MPMY-PM-PRC-
8.7
Pipeline internal 0008)
Uploaded RBI
programme for first 5
years in CMMS and AI
System Anomaly
Management
Procedure
API RP 2A
API RP 2SIM

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APPENDIX B: ORGANIZATION CHART FOR O&M AND ASSET INTEGRITY DURING EXECUTE PHASE

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