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    OGP 1

    This supplement to OGPs document Process Saety Recommended Practice on Key PerormanceIndicators (Reerence No. 456) contains examples adapted or upstream operations rom the API RP754standard and rom OGP member companies. These 65 examples provide an important aid or interpret-ing the guidance and are ocused on Tier 1 and Tier 2 PSE because these data will be reportable bycompanies to OGP. This document is downloadable rom http://www.ogp.org.uk/pubs/456supp.pdf and will be up-dated when the OGP Process Saety Sub-Committee or individual companies provide urther examples.

    Types o events covered by these examples include:

    Injury or atality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Fire or Explosion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

    Loss o Primary Containment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

    Acute Release (within any one-hour period) . . . . . . . . . . . . . . . . . . . . . . . 6

    Pressure Relie Device . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

    Pipelines and Flowlines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

    Marine and Land Transport. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

    Destructive Devices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

    Vacuum Truck Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

    Evacuation or Shelter-in-Place. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

    Drilling Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

    Proc afeyUpsram PSE xampl

    International Association of Oil & Gas Producers

    Report No. 456supp, Nov 2011

    Disclaimer

    Whilst every eort has been made to ensure the accuracy o the inormation contained in this publi-cation, neither the OGP nor any o its members past present or uture warrants its accuracy or will,regardless o its or their negligence, assume liability or any oreseeable or unoreseeable use madethereo, which liability is hereby excluded. Consequently, such use is at the recipients own risk on thebasis that any use by the recipient constitutes agreement to the terms o this disclaimer. The recipient isobliged to inorm any subsequent recipient o such terms.

    Copyright notice

    The contents o these pages are The International Association o Oil and Gas Producers. Permissionis given to reproduce this report in whole or in part provided (i) that the copyright o OGP and (ii) the

    source are acknowledged. All other rights are reserved. Any other use requires the prior written permis-sion o the OGP.

    These Terms and Conditions shall be governed by and construed in accordance with the laws o Englandand Wales. Disputes arising here rom shall be exclusively subject to the jurisdiction o the courts oEngland and Wales.

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    OGP2

    Injury or atality

    Example Reporting

    1

    An operator walks through a process unit and slips and alls to the ground and suers in an occu-pational injury which was a lost work day case (LWDC). The slip/all is due to weather conditions,chronic oily oors and slippery shoes. This is not a Tier 1 or Tier 2 PSE. Personal saety slip/trip/all incidents that are not directly associated with evacuating rom or responding to a LOPCare specifcally excluded rom the KPI.

    LWDC but not a PSE(see 3.5, point )

    2

    Same as above, except that the operator slipped and ell while responding to a small spill o liquidwith a ash point

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    OGP 3

    Fire or Explosion

    Example Reporting

    8

    An over-pressure in a process vessel causes equipment damage > $25,000, but there was no losso containment. While this is a serious process event and should be investigated as such, it doesnot meet the KPI defnition o a Tier 1 or 2 PSE because there was no LOPC involved.It is good practice to report, classiy and investigate other types o asset integrity or process eventswith actual or potentially serious consequences using the internal reporting mechanisms o the Com-pany and its acilities. This would include locally defned Tier 3 KPIs.

    Not a PSE(Tier 3 KPI)

    9

    A scaold board is placed near a high pressure steam pipe and subsequently begins to burn, butis quickly extinguished with no urther damage. The investigation fnds that the board had beencontaminated by some oil, but there is no indication o an oil leak in the area. This is not a PSEsince there was no unplanned or uncontrolled LOPC, but is may be a reportable incident underother company or acility KPIs.

    Not a PSE

    10

    An electrical fre impacts the operation o the process resulting in an acute release outdoors o

    3,300 lbs (i.e. 1500kg or about 10 bbl) o light crude oil (API Gravity ca. 40, ash point

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    OGP4

    Loss o primary containment

    Example Reporting

    17

    Ten barrels o ammable gas condensate (1,400 kg, 3,100 lbs.) leak rom piping onto concreteand the hydrocarbons do not reach soil or water. Site personnel estimate that the leak occurredwithin one hour. This is a Tier 1 PSE because there was a LOPC o 7 bbls (1,000 kg, 2,200 lbs.) ormore o Category 6 ammable liquid with a ash point

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    OGP 5

    Example Reporting

    24

    There is a tube rupture in a fred heater causing a fre (contained in the heater) resulting in greaterthan $25,000 in damages to the heater internals (beyond that o replacing the ailed tube). Thetube ailure is a loss o primary containment o the process uid and combined with the additionaldamages greater than $25,000 makes this a Tier 1 PSE.

    Tier 1 PSE (see AppendixA, Table 1)

    Same as above, except the operator detects the tube cracking with only a small ame rom thetube and subsequently shuts down the heater with no resultant damage rom the tube ame. I theestimated amount o material released is below the threshold quantities in Appendix A, Page 2, thiswould be not be a Tier 1 or 2 PSE. However this near-miss event could be reported within the Tier3 KPIs o the company or acility.

    Possible Tier 3 KPI

    25

    An operator is draining water o a crude oil tank with a ash point o 60C (140F) or less (or anAPI Gravity o 60C (140F) at atemperature below its ash point into an oily water collection system within one hour as part o avessel cleaning operation. Since the drainage is planned and controlled and the collection systemis designed or such service, this is not a reportable Tier 1 or 2 PSE.

    Not a PSE

    I the material released had been unplanned or uncontrolled and owed to an open drain, seweror other collection system, it would be a reportable Tier 2 PSE based on the threshold quantity andmaterial below its ash point.

    Tier 2 PSE (see AppendixA, Table 4)

    27

    A valve leak occurred in a gas turbine acoustic enclosure (or a valve box) which is accessible to theworkorce. The quantity o gas released was 40kg. This is a Tier 2 PSE, because the LOPC exceedsthe threshold quantity or an indoor release o ammable gas. I equipment or a work area is en-closed (apart rom louvers and/or air intakes) then the indoor release threshold quantities should beused or determining whether an LOPC occurring in any one hour period is a Tier 1 or Tier 2 PSE.

    Tier 2 PSE (see AppendixA, Tables 2 & 4)

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    OGP6

    Acute release (within any one-hour period)

    Example Reporting

    28

    There is a 10 bbl spill o condensate that steadily leaks rom piping onto soil over a two-week timeperiod. Simple calculations show the spill rate was approximately 0.03 bbls per hour. This is nota Tier 1 or Tier 2 PSE since the spill event did not exceed the threshold quantity in any one-hourperiod. However this event can be reported within the Tier 3 KPIs o the company or acility.

    Possible Tier 3 KPI

    Same example as above, except that the 10 bbl leak was estimated to have spilled at a steady rateover a period o 1 hour and 30 minutes. Simple calculations show that the spill rate was 6.7 bblsper hour. The spill rate was less than the reporting threshold o 7 bbls within 1 hour or a Tier 1 PSEbut it does meet the threshold o 1 bbl within 1 hour, thus it is a Tier 2 PSE.

    Tier 2 PSE (see AppendixA, Tables 2 & 4)

    29

    An operator discovers an approximate 10 barrel liquid spill o light crude oil (ash point 15) near a process exchanger that was not there during his last inspection round twohours earlier. Since the actual release duration is unknown, a best estimate should be used to deter-mine i the Threshold Quantity rate has been exceeded (it is preerred to err on the side o inclusion

    rather than exclusion). This incident is a Tier 1 PSE because the crude oil involved is a Category 6ammable liquid and the threshold quantity o 7 barrels is exceeded i the time period is estimatedto be less than one hour.

    Tier 1 PSE (see Appendix

    A, Table 4)

    30

    While troubleshooting a higher-than-expected natural gas ow rate, operating personnel fnd anopen block valve on the natural gas line releasing to an elevated vent location. Upon urther inves-tigation, it is determined that a total o 1 million lbs. o natural gas was relieved at a steady rateover a 6 month period. This is not a Tier 1 PSE as the release rate (~100kg per hour) did not ex-ceed the threshold quantity o 500kg or more within one hour); however, it is a Tier 2 PSE becauseit did exceed the threshold o 50kg or more within 1 hour.

    Tier 2 PSE (see AppendixA, Table 4)

    31

    Inrared scans identifed that the separator oatation treater was leaking 10,000 SCFD o gas romthe agitator seals. The separator continued to operate or 10 days until the treater was taken out oservice and its seals replaced. Unlike the next example, this LOPC is not a PSE because the leakagerate was less than the Tier 2 release threshold or ammable gas 50kg (110 lb) in one hour, i.e.this was not considered an acute release.

    Not a PSE (see Concepto an Acute Release,Section 3.2)

    32

    While troubleshooting a higher-than-expected natural gas ow rate, operating personnel fnd asaety valve on the natural gas line that did not reseat properly and was relieving to the atmospher-ic vent stack through a knock-out drum. Upon urther investigation, it is determined that a total o 1million lb o natural gas was relieved at a steady rate over a 6-month period. This is a LOPC whichmeets the criteria or a Tier 2 PSE because the release rate o about 100kg per hour exceeds thethreshold quantity o 50kg or more within 1 hour, i.e. this is still considered an acute release.

    Tier 2 PSE (see AppendixA, Tables 2 & 4 andConcept o an Acute

    Release, Section 3.2)

    33

    A pipe containing CO2 and 10,000 vppm H2S (1% by volume) leaks and 7,000kg (15,400 lbs)o the gas is released within an hour. Calculations show that the release involved about 55kg (120lbs) o H2S (TIH Zone B toxic hazardous material). The release is a Tier 1 PSE because it exceededthe threshold quantity.

    Tier 1 PSE (see Appen-dix A, Tables 2 & 5)

    I the H2S concentration is 50vppm, then the calculated release quantity would be 0.3kg o H

    2S.

    The release would not be a Tier 1 or Tier 2 PSE since this amount is below the 25kg (55 lbs) and2.5kg (5 lbs) thresholds or H2S. However, this LOPC event could be reported within the Tier 3 KPIso the company or acility.

    Tier 3

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    OGP 7

    Pressure relie device

    Example Reporting

    34

    There is a unit upset and the PRD opens to an atmospheric vent that has been designed per APIStandard 521 or that scenario, resulting in a release o 300 lbs. o propane to the atmospherewith no adverse consequences. Although it exceeded the Tier 2 threshold quantity, because it didnot result in one o the defned negative consequences, it is not a Tier 2 PSE. A company using aTier 3 KPI to track demands on saety systems would report this event since it is an activation o aPRD that was not counted in Tier 1 or 2.

    Possible Tier 3 KPI (seeSection 4.1, Example 2)

    Same as above, but there was an onsite shelter in place. This is a Tier 2 PSE because it both ex-ceeded the threshold quantity and resulted in one o the defned negative consequences.

    Tier 2 PSE (see AppendixA, Table 3 & 4)

    35

    A sour gas scrubber has a PRD that was identifed in a recent PHA to be undersized. During normaloperations, the scrubber overpressures. A release o 60 pounds o H 2S gas (TIH Zone B material)occurs through this PRD is directed to the are system over a period o 25 minutes. This wouldnot be a Tier 1 or Tier 2 PSE, regardless o the PHA fnding, so long as it did not result in a liquid

    carryover, onsite shelter in place, public protective measure or other indication o discharge to anunsae location (Appendix A, Table 3). A company using a Tier 3 KPI to track demands on saetysystems would report this event as an activation o a PRD resulting in a release to atmosphere via adestructive device.

    Possible Tier 3 KPI (see

    Section 4.1, Example 2)

    36

    A relie valve operates and vents 250kg o ammable gas directly to the atmosphere with a smallliquid carryover estimated at 10kg o hydrocarbon. This is a Tier 1 PSE because there was liquidcarryover and because the total mass released exceeds the threshold quantity (i.e. not just the masso the liquid or the mass o the gas) and major component o the material is fammable gas (APIRP754 Category 5).

    Tier 1 PSE (see AppendixA, Tables 3 & 4)

    37There is a unit upset and the PRD ails to open, resulting in overpressure o the equipment and a10-minute release o 2200lbs/1000kg o C3-C5 hydrocarbons (ammable gas, Category 5) roma leaking ange beore it can be blocked in. This is a Tier 1 PSE.

    Tier 1 PSE (see AppendixA, Tables 2 & 4)

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    OGP8

    Pipelines and fowlines

    Example Reporting

    38

    A pipeline operated by the company leaks and releases 2,200 lbs/1000kg o ammable gasabove ground within one hour; however, the release occurred in a remote location and not on aacility. This is a reportable Tier 1 PSE since remoteness is not a consideration and the releaseexceeded a Tier 1 threshold quantity.

    Tier 1 PSE (see AppendixA, Tables 2 & 4)

    39

    A pipeline leaks and releases 2,200 lbs/1000kg o ammable gas above ground within 1 hour. Apublic road bisects the main acility and its marine docks. This pipeline originates in the acility andgoes to the docks. The leak site happens to be o the sites property in the short segment o pipingthat runs over the public road. Although the leak technically occurs o-site, this is a Tier 1 PSE sincethe acility owns and operates the entire segment o pipeline.

    Tier 1 PSE (see AppendixA, Tables 2 & 4)

    40

    A third-party truck loaded with a ammable liquid is traveling on Company premises and experi-ences a leak and subsequent fre and property damages o $75,000 (direct costs). The incidentwould not be a Tier 1 or Tier 2 PSE because truck incidents are excluded, except when they are

    connected to the process or the purposes o eedstock or product transer.

    Not a PSE (see section3.5, point a.)

    Same as above except, the third party truck is parked and being used or temporary onsite storage.This would be a Tier 1 PSE since the applicability exclusion does not include the use o trucks orrailcars or onsite storage.

    41

    There is a 200 bbl spill rom a owline containing light crude with a ash point

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    OGP 9

    Marine and land transport

    Example Reporting

    44

    A Company operated Marine Transport Vessel that had just disconnected rom an oshore rig hasan onboard 14 bbl spill o drilling uids with a ash point > 60 C (140 F) released at a tempera-ture below its ash point. The event is not a PSE since Marine Transport Vessel incidents are specif-cally excluded, except when the vessel is connected to the process or the purposes o eedstockor product transer. This is likely to be a reportable spill to the environment within other KPIs o theCompany.

    Not a PSE (See Section3.5, point a.)

    I the marine transport vessel was still connected to the rig when the spill occurred, it would be aTier 2 PSE.

    Tier 2 (see Appendix A,Tables 2 & 4)

    45A third-party barge is being pushed by a tug and hits the Company dock. A barge compartment isbreached and releases 50 bbls o diesel to the water. This LOPC event is not a PSE since the bargewas not connected to the process or the purpose o eedstock or product transer.

    Not a PSE (See Section3.5, point a.)

    46A marine survey boat is pulling a tube screen or seismic survey and a shark bites into the tubereleasing 7 bbl o hydraulic uid into the water. This LOPC event may be a reportable spill to theenvironment but not a PSE because exploration activities are not within scope or the OGP AssetIntegrity PSE KPIs.

    Not a PSE (see Section3.4)

    47A Company railcar derails and spills more than 7 bbls o gasoline while in transit. The LOPC eventis not a PSE since it is not connected to the process or the purpose o eedstock or product transer,but this is likely to be a reportable spill to the environment within other KPIs o the Company.

    Not a PSE (See Section3.5, point a.)

    48A third-party truck/trailer on Company premises has a spill o gasoline greater than 7 bbls in lessthan an hour while loading. The incident is a Tier 1 PSE since the truck was connected to the pro-cess or the purpose o eedstock or product transer.

    Tier 1 PSE (see AppendixA, Tables 2 & 4)

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    OGP10

    Destructive devices

    Example Reporting

    49

    The are system is not unctioning properly due to inactive pilots on the are tip. During this time,ammable gas is sent to the are due to an overpressure in a process unit. The volume o the unlitvapor released to the atmosphere through the are is greater than the Tier 1 threshold. This wouldbe classifed as a Tier 1 PSE since this the downstream destructive device did not unction correctlyand an unplanned/uncontrolled discharge (LOPC) resulted exceeding a threshold release quantity.

    Tier 1 PSE (see AppendixA, Tables 2 & 4)

    50

    100 bbls o crude oil are inadvertently routed to the are system through a PRD. The are knockoutdrum contains most o the release; however, there is minimal liquid phase hydrocarbon rainout.This is a Tier 1 PSE since the volume released rom the PRD to a downstream destructive deviceexceeds the threshold quantity in Table 1 and resulted in one o the our listed consequences (i.e.liquid carryover).

    Tier 1 PSE (see AppendixA, Tables 3 & 4)

    51A PRD release o sour gas less than Tier 1 threshold quantity is routed to a are which exposes twopersonnel to toxic SO2/SO3 vapors resulting in a lost work day case (LWDC) incident. This is a

    Tier 1 PSE since the PRD discharge resulted in a days away rom work injury.

    Tier 1 PSE and a LWDC(see Appendix A, Table

    1)

    52

    A propane tank over-pressures through a PRD to the are system. The pilots on the are system arenot working properly, and the are does not combust the vapors. The event transpires over a periodo 45 minutes. The volume o propane release was estimated to be 1300 pounds (ca. 600 kg) andthe release dissipated into the atmosphere above grade and above any working platorms. Theamount o PRD discharge and resultant unintended propane release rom the are exceeded theTier 1 threshold quantity. This is a Tier 1 PSE since the are did not unction correctly and a LOPCresulted in a release above Tier 1 thresholds.

    Tier 1 PSE (see AppendixA, Tables 2 & 4)

    I the are operated correctly, a company using a Tier 3 KPI to track demands on saety systemswould report this event as an activation o a PRD resulting in a release to atmosphere via a down-stream destructive device.

    Possible Tier 3 KPI

    53

    An upset causes a PRD to open and release uel gas to the acility are system. The are system

    works properly and combusts the vapor release which came rom the PRD. This is not a Tier 1 orTier 2 PSE since the PRD release was routed to a downstream destructive device that unctioned asintended (i.e., did not cause one o the our listed consequences).Depending on its KPIs, a company may record this demand on the saety system as a Tier 3 event.

    Possible Tier 3 KPI

    Vacuum truck operationsExample Reporting

    54

    Ater collecting a load rom an adjacent unit, a vacuum truck is parked at the wastewater treatmentacility awaiting operator approval to discharge. While waiting the vacuum truck malunctionsand vents process material to the atmosphere. This is not a PSE since vacuum truck operations areexcluded unless loading, discharging or using the trucks transer pump.

    Not a PSE (see Section3.5, point c.)

    55

    A vacuum truck outftted with a carbon canister on the vent is loading a spill o hydrocarbons. The

    carbon canister catches fre which escalates to the point o creating more than $10,000 in dam-age to the vacuum truck. This is a Tier 2 PSE since the original spill o hydrocarbons constitutes theLOPC and the response to the LOPC results in one o the Tier 2 consequences.

    Tier 2 PSE (see AppendixA, Table 1)

    Same as above except the vacuum truck is connected to the process. This is a Tier 2 PSE due to$10,000 fre damage. The excess o hydrocarbon vapors absorbed by the carbon canister is theuncontrolled LOPC.

    Tier 2 PSE (see Section3.5, point c.)

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    OGP 11

    Evacuation or shelter-in-place

    Example Reporting

    56

    A small quantity o methyl mercaptan or odorizing natural gas inadvertently enters a cooling watersystem via tube leak. The material is dispersed into the atmosphere at the cooling tower. An elemen-tary school teacher decides not to conduct recess outside due to a noticeable odor even thoughofcials deemed no shelter-in-place was necessary; thereore, this is not a Tier 1 or Tier 2 PSE. Thesite may choose to capture this event as a Tier 3 other LOPC.

    Possible Tier 3 KPI

    57

    A pressure relie device (PRD) discharges to a scrubber that vents to atmosphere. The scrubber isoverwhelmed by a ow rate greater than its design resulting in a discharge that is detected byence-line monitoring and a public shelter-in-place order is issued. The PRD release quantity is esti-mated to be less than the Tier 1 thresholds. This is a PSE with a Tier 1 consequence regardless othe quantity released exceeding a threshold quantity because o the ofcially declared communityshelter-in-place

    Tier 1 PSE (see AppendixA, Table 1)

    58

    A pressure relie device (PRD) activates resulting in a substantial release exceeding Tier 1 thresholds

    on an oshore platorm causing precautionary down-manning or platorm abandonment (someor all o the workorce). This is equivalent to an onshore situation resulting in an onsite shelter inplace and would be a Tier 1 PSE.Mustering oshore to a sae location on the platorm is not considered a sufcient consequence totrigger reporting a Tier 1 or 2 PSE.Equally the partial evacuation o an onshore gas plant to a sae muster point, on-site or o- site, isalso considered a shelter-in-place consequence which would result in a Tier 1 or Tier 2 PSE ol-lowing LOPC which meets or exceeds the threshold quantities in Appendix A.

    Tier 1 PSE (see AppendixA, Tables 3 & 4)

    59

    Less than 1 pound o Hydrogen Sulphide gas is released while loading a molten sulphur car. Therelease is detected by a local analyzer and triggers a unit response alarm. An o-duty policeofcer living in a nearby home advises his neighbors to evacuate because an alarm like thatmeans theres a problem at the plant. This is not an ofcially declared evacuation or shelter-in-place because in this situation the ofcer is acting as a private citizen suggesting a precautionary

    measure; thereore this is not a Tier 1 or Tier 2 PSE. The site may choose to capture this event as aTier 3 LOPC.

    Possible Tier 3 KPI

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    OGP12

    Drilling operations

    Example Reporting

    60

    A drilling subsurace blow-out comes to surace (along the casing or along another path to thesurace) resulting in a release o over 10 tonnes o ammable gas to atmosphere in 15 minutes.This LOPC is a PSE and would be classifed as Tier 1 because the threshold quantities were clearlyexceeded in a period o less than 1 hour.

    Tier 1 (see Appendix A,Tables 2 & 4)

    61

    A steam injection well ails with an explosion resulting in release o 10 tonnes o uids, a mixture ohydrocarbons and water. The direct cost o replacing and repairing damaged equipment was esti-mated at $300,000 and a worker was injured, needing medical treatment. The ailure is a Tier 1Process Saety Event, because it is a LOPC that resulted in an explosion resulting in over $25,000o direct cost.

    Tier 1 PSE (see Appen-dix A, Table 1) and arecordable injury

    As above, but without the explosion. The recordable injury resulting rom the LOPC would requireat least a Tier 2 PSE be reported. I the amount o hydrocarbon released met or exceeded any Tier

    1 threshold in Appendix A, Table 4, then a Tier 1 PSE will still be reported. The estimate o materialreleased should exclude the amount o water as there is no threshold quantity or water.

    Tier 1 PSE (see AppendixA, Tables 2 & 4) or Tier2 PSE (See Appendix A,

    Table 1) and a record-able injury

    62

    During an extended well test at 10,000 Barrel Per Day rate with 1250 gas-to-oil ratio, a slug oliquid extinguished the are ame resulting in a release o uncombusted natural gas at 520,000SCF per hour until the are was reignited 10 minutes later.This is a Tier 1 PSE because the are ailed to operate as designed when it amed out resulting inan unplanned and uncontrolled release (LOPC) o ammable gas signifcantly exceeding the Tier 1release quantity o 1100 lb (500 kg) within one hour.

    Tier 1 PSE (see AppendixA, Tables 2 & 4)

    63

    While drilling a well there was a loss o hydrostatic overbalance. The result o the loss o hydrostat-ic overbalance resulted in a well kick. Standard Well Control procedures were implemented to re-establish ull well control. These procedures resulted in the planned venting o the kick through therigs choke and kill system and de-gasser. No ammable impacts were observed on the rig or area.This was a planned release consistent with procedures and thereore not a Tier 1 or Tier 2 PSE eventhough the gas release may have exceeded the release quantity thresholds or the PSE KPI.Companies may report this within their Tier 3 KPIs because this is a demand on a saety system ora PRD activation

    Possible Tier 3 KPI

    64

    While drilling a well, a shallow gas pocket was struck, causing a loss o well control. Mud, cuttingsand 100 barrels o oil were released to the environment, and 1.8 MMSCF o gas (about 64,000kg) were discharged through the diverter valve to the atmosphere. The release continued or twodays at an average o 900,000 SCFD. This meets the criteria or both a Tier 1 PSE because o theammable gas LOPC. It is also a reportable spill over 1 Barrel to the environment under companysenvironmental reporting requirements.

    Tier 1 PSE (see AppendixA, Tables 2 & 4) and areportable oil spill to theenvironment

    65

    100 kg (220lb) o diesel uel spills within an enclosed area during a period o 30 minutes whiletranserring uel to a drilling platorm while in-hole. A LOPC while connected to a platorm whenin-hole is reported as a process saety event. This would be a Tier 2 PSE because the uel systemon a platorm is considered part o the process, and the spill exceeds the 50kg indoor thresholdquantity or Tier 2 or ammable liquids (RP 754 Category 6).I the spill occurred during transer o uel to a MODU (e.g., jack-up or drill ship) contracted tocarry out drilling operations at a company well site, this would also be included as a PSE, asabove. However, i the spill occurred when the MODU under contract was moving between wellsites then the activity is not in-hole and would not be considered connected to the process andwould not be a PSE.

    Tier 2 PSE (see AppendixA, Tables 2 & 4)