Simply 2SIM - Cougar Offshore LLC

Cougar Offshore

Simply 2SIM - API RP 2SIM.docx

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Simply 2SIM

DARREN J MORAHAN

COUGAR OFFSHORE LLC

FOREWARD

This document has been prepared for those interested in the background and methodology of

implementing a risk based approach to platform inspection as outlined in API RP 2SIM. Cougar Offshore

presently manages one of the largest, if not the largest, fleet based inspection programs in the Gulf of

Mexico covering over 20% of the existing fixed platforms utilizing a risk based approach commensurate

with the guidance provided in 2SIM.

INTRODUCTION

Since the issuance of API RP 2SIM in November 2014, there is increasing rhetoric on the complexities of

the code leading up to the indicated adoption of the guidance by BSEE on 1st November 2015. 2SIM

provides guidance on the implementation of a Structural Integrity Management (SIM) approach for the

planned maintenance and inspection of fixed offshore platforms. While the International Standards

Organization (ISO) is working on international guidance covering SIM, 2SIM is specific to the Gulf of

Mexico and US West Coast. 2SIM has simply expanded on Section 14 (Surveys) and Section 17

(Assessment) of API RP 2A 21st Edition with additional sections covering SIM, damage evaluation, risk

reduction and decommissioning. The increased interest comes from conferences organized to

'enlighten' those interested, companies offering 'expertise' in implementing a SIM system and from

operators wishing to benefit from lowered risk and significant cost savings a good SIM system should

enable.

Simply put, a SIM system will target inspection by the selection of inspection intervals commensurate

with risk associated with likelihood of failure and consequence of failure. 2SIM goes further by providing

greater guidance on the inspection types and scopes of work. The content of 2SIM provides far more

guidance than that contained in API RP 2A but the overall intent and methodology remains the same

with regard to surveys and assessment. 2SIM allows the operator to select a 'default' inspection

approach or a risk based approach to inspection. The default simply is based on the defined inspection

intervals based on platform consequence of failure and inspection level as with API RP 2A. A Risk Based

Underwater Inspection (RBUI) is where 2SIM provides guidance not previously available and thus

inspection intervals are selected based on risk utilizing the inspection interval ranges provided. In

addition, API RP 2A provided base or default inspection intervals for Level II and Level III underwater

inspection, which 2SIM also does, however, 2SIM allows more flexibility on when those Level III

inspections can be carried out. This is significant because it leaves it to the operator to utilize and justify

a methodology that can combine the Level III inspections with the Level II inspections resulting in a

significant cost saving.

Another area of potentially significant savings when developing an inspection program is the use of

Flooded Member Detection (FMD) during a Level III inspection which 2SIM provides greater guidance on

compared to API RP 2A. The proper use of FMD is significantly less costly compared to Close Visual

Inspection (CVI) of jacket joints, should encompass many more members and should provide far greater

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information on the structural integrity of a jacket. However, this raises a key competency requirement

of an effective SIM system to ensure the inspection scopes of work yield the most cost effective and

meaningful inspection results. The effectiveness of FMD relies on the appropriate selection of members

and a sufficient number. FMD is significantly more effective because far more often than not FMD will

detect damage when CVI will not simply because defects or cracks that can cause flooding are not

detected.

BACKGROUND

The Structural Integrity Management of offshore structures has been a concept utilized to efficiently

manage the inspection, maintenance, repair and decommissioning of platforms effectively for over two

decades. First implemented in the North Sea, it was a tool developed for large offshore platforms. A

fleet based approach can realize significant benefits from the lowered risk and the efficiencies. Thus, the

applicability for Gulf of Mexico platforms was self-evident given the size of operator fleets which far

exceed any other oil and gas region. API RP 2A 21st edition gives a cursory mention to SIM in the

commentary and provides no guidance on the methodology to implement a SIM system applicable in

the GOM. A hand full of GOM operators, mainly confined to a few super majors, implemented a SIM

system based on knowledge at the time and with little guidance from codes. Many platforms that were

managed in a SIM system experienced significant damage if not full collapse during the hurricanes

Katrina, Rita and Ike. Although it is accepted that platforms will experience damage or complete collapse

during a hurricane, many of these platforms were not considered high risk from collapse. A number of

studies have been undertaken to determine why some platforms failed while others did not and why

low risk platforms failed when 'high risk' platforms did not. There are many factors that contribute to

the robustness of a platform and unless a SIM system is calibrated and utilizes a rational that ranks

platform robustness effectively the ranking is meaningless. This becomes particularly important for a

number of reasons as follows:

Operators may self-insure or selective insure assets so knowing which are the important and

higher risk platforms is critical. Due to the overwhelming financial burden a number of operators

divested assets and even the majority or complete platform fleet post hurricane because the

risk model developed as part of a SIM system resulted in the loss of many important platforms

that were not insured.

Leading on from the previous point, insurance companies will no doubt re-address insurance

coverage as operators implement a risk based approach provided in 2SIM. With the advent of

2SIM insurance companies will be asking for the risk based methodology for comparison with

their own internal assessment(s), particularly for fleet wide coverage.

An effective SIM system relies on the risk ranking for likelihood of failure and consequence of

failure to target inspections proportionate with those risks. It is pointless and an unnecessary

use of resources to inspect platforms using intervals that are shorter than other platforms with

higher risk.

As companies begin to embrace the new 2SIM guidance a number of contractors are offering services

that encompass the Structural Integrity Management of platforms. Competencies and previous

experience are all the more important to ensure a good working solution that assigns risk

commensurate with structural robustness, consequence of failure and importance. Previous experience

does not necessarily mean it is based on structural knowledge, offshore experience, fabrication

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experience, strengthening and repair or inspection and should be questioned on the performance and

existing status of operator fleets.

IMPLEMENTING API 2SIM

To those not familiar with SIM and RBUI, 2SIM can appear overly complex; however, the principles are

straight forward. The complexity really comes from the use of many terms and descriptions that detract

from the base intent of 2SIM. Additional levels of life safety and consequence of failure have been

introduced in 2SIM that were not in API RP 2A which can give the impression of increased complexity,

however, the two are essentially the same with greater details simply provided in 2SIM to aid in the

appropriate allocation of risk.

Implementation of 2SIM is really very straightforward. Much of the data required is readily available.

Complex SIM systems will greatly increase the effort required to implement 2SIM for a fleet of platforms

unnecessarily. These systems often require an inordinate amount of user time to simply maintain and

input data. A far more efficient system should be adaptable to client needs, such as reporting, while

providing the core requirements of a functioning system. In fact, for operators that have been using a

SIM approach to inspection planning, they should experience little impact in changing from API RP 2A to

2SIM. The changes should be confined to inspection intervals and methodology for inclusion of Level III

inspections with Level II inspections.

The core of a functioning SIM system is the development of a RBUI strategy. Data input, data evaluation,

assessment, damage evaluation, CP evaluation and risk reduction are all part of the SIM process,

however, the effectiveness of a SIM system relies on the appropriate risk ranking and inspection

strategy. Without the inspections, there is limited data on present condition on which the other areas

rely and inspection intervals should be commensurate with risk. It is therefore important to define the

risk matrix. 2SIM provides a basic recommendation of a 3 x 3 matrix, however, to appropriately assign

risk across a fleet of platforms with varied function and size a more detailed matrix (5 x 3) is

recommended. Keeping with the 3 levels of consequence the matrix is expanded to cover, as a

minimum, 5 levels of likelihood of failure. Experience has shown that more than 5 levels simply create

more complexity that is unnecessary and has little to no benefit. A suggested risk matrix therefore is

presented in Figure 1.

Consequence

of Failure

L-1 M M H H H

L-2 L M M H H

L-3 L L M M M

V. Low Low Medium High V. High

Likelihood of Failure

Figure 1 SIM Suggested Risk Matrix

The content of each cell can be debated, however, risk must be assigned according to the consequence

of failure and likelihood of failure accordingly e.g. a medium risk L-1 platform should have a higher

assigned risk than a V. High L-3 because of platform importance.

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Based on the suggested inspection intervals contained in 2SIM and presented in Figure 2, a suggested

inspection interval matrix is derived as presented in Figure 3.

Risk

Category

Inspection

Intervals

(yrs)

High 3 5

Medium 6 10

Low 11 15

Figure 2 2SIM Suggested Inspection Intervals

Consequence

of Failure

L-1 10 7 5 4 3

L-2 12 9 7 5 4

L-3 15 12 10 8 6

V. Low Low Medium High V. High

Likelihood of Failure

Figure 3 SIM Suggested Inspection Intervals

Utilizing a defined inspection interval matrix and the determined likelihood of failure, risk ranking in

addition to the defined consequence of failure, an inspection strategy is developed from which a

program is generated. Of course the process has been simplified, but the methodology outlined forms

the basis of a functioning RBUI strategy. Other factors such as the definition of consequence of failure

require a systematic approach which can include business determined criteria as well as criteria defined

in 2SIM.

SIM BENEFITS

The benefits of a functioning SIM system have been touched on. 2SIM enables further benefits at

negligible additional effort. A functioning SIM system can be implemented at minimal cost per platform

while yielding significant cost savings and reduced overall risk. In summary:

Central source of data for evaluations, reporting (OSTS) and data presentation.

Targeted underwater inspection commensurate with platform risk.

Extended default inspection intervals according to platform risk amongst a fleet of platforms.

A functioning SIM system should reduce in cost per platform as the fleet size increases.

The SIM system should function at less than $500 / platform / year and reduce as fleet size

increases.

For a fleet of platforms, an inspection cost saving per platform in the order of $3,000 per year

should be realized when comparing RBUI intervals to default inspection intervals.

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COUGAR OFFSHORE LLC SIM BENEFITS

To summarize the benefits of Cougar Offshores SIM system, which is fully compliant with API RP 2SIM,

the following is provided:

Small independent company providing face time with developers/workers on system, decisions

made in meetings and no middle men.

Fast turnaround time on information requests (far simpler than web based systems).

Personalized data presentation per each end user requirements/wishes.

Adaptability and personalization for each company. Fast efficient implementation of client

desires.

Ready ability to further refinement of risk ranking system based on business importance of

platforms.

System transparency i.e. no black box associated with complex and/or web based systems.

Significantly reduced OSTS preparation costs due to centralized data source.

Extensive experience with damage reviews and monitoring, repair techniques and in depth

knowledge of structural assessment and repair. Tracking of damage from inspection to

repair/monitoring.

Yearly inspection SOW program, efficient, lower cost and database retention of past inspection

program results.

Should you have any questions please do not hesitate to make contact:

Darren J Morahan

President/CEO

Cougar Offshore LLC

Houston, TX

281 725 0942

www.cougaroffshore.com

[email protected]

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Simply 2SIM - Cougar Offshore LLC