Health and Safety Executive Hid Semi Permanent Circular Hazardous Installations Directorate SPC/TECH/OSD/31
Health and Safety Executive Hid Semi Permanent Circular Hazardous Installations Directorate SPC/TECH/OSD/31
TO: OSD Inspectors [Bands 1-3] and all HID SI3 Inspectors
PURPOSE
ACTION
Inspectors should take account of the contents of this SPC when undertaking the
assessment of safety cases and the inspection of pipelines and process pressure
systems.
INTRODUCTION
2. Some Duty holders use alternative terms for HIPPS, eg Over Pressure
Protection System [OPPS].
ANNEXES
5. HSE has encountered several tens of HIPPS which provide topside protective
functions. Often topside HIPPS have been implemented in situations where
the ratio between the maximum pressure threat and rated pressure is
below 1.5. In such cases the hydrotest pressure will not be breached and
there is a relatively low risk of loss of containment.
7. The critical plant protected by a pipeline HIPPS has generally been the
remote import riser and associated pipework. HIPPS are attractive for high
pressure/high temperature [HP/HT] developments where:
a. It is not possible to design the pipeline and risers to the full well
closed-in tubing head pressure [CITHP]; or
b. The pipeline is so long that rating the pipeline for the CITHP, though
possible, renders the project uneconomic.
9. HIPPS protected pressure systems may include high inventory pipelines and
risers, the failure of which is a major hazard. Particular aspects regarding the
of use of remotely located HIPPS include:
b. For installations which are manned there is scope to close valves manually
in order to isolate a local pressure source in the event of a HIPPS mal-
function and so prevent overpressurisation of downstream installations.
Generally a NUI or subsea pressure source will be able to be isolated
remotely from a downstream manned installation. However if problems are
encountered in achieving a prompt isolation of the pressure source, e.g. a
loss of the control system, then the period of time required for
transportation of technicians to the NUI for manual intervention becomes
important.
11. The preferred design option is that of inherent safety, ie risers are to be fully
rated to maximum pressure to which they may be subjected. Where the
inherently safe option is judged not to be reasonably practicable then the
pipeline should be protected by a pressure relief system. Any deviation from
these design options should be justified within an ALARP demonstration.
In assessing the safety of different options, it should be noted that relief
valves deliver their primary safety function with considerable reliability, and
have different failure modes from instrumented trips, thus giving a useful
degree of diversity which a HIPPS solution lacks.
12. Where the inherent safety and the pressure relief options are not judged to be
reasonably practicable then protection may be afforded by an appropriate
instrumented protective system comprising an HIPPS as a backup to the
Emergency Shutdown System [ESD]. Both systems are to be capable of
independently isolating the over-pressure hazard with the HIPPS normally
having a greater design reliability than the ESD:
f. provide means to avoid blockages [eg hydrates], which will reduce the
number of demands on the over pressure protection systems.
LEGAL CONSIDERATIONS
13. A pipeline rupture is a safety issue only if it occurs near people [or in the
longer term, if people have to do potentially dangerous things to rectify the
situation]. Thus in practice, only a rupture of a pipeline near an installation or
at the riser itself is a major hazard issue. For pipeline sections remote from
offshore installations shipping activity may be minimal, and therefore vessels
are unlikely to be threatened by any release.
15. Prevention of Fire and Explosion and Emergency Response Regulations 1995
[SI 1995/743]
a. Regulation 9(a). Ensure the safe … handling and movement of….
flammable or explosive substances.
[Note that a subsea HIPPS is not considered to be a SCE since it is not part
of an installation. A HIPPS on one installation protecting risers under another
installation is a safety critical element, but the practicalities of verifying such
elements are not simple, particularly when the installations concerned have
different operators.]
17. Management of Health and safety at Work Regulations 1999 [SI 1999/1877]
Note that Schedule 1(e) includes the goal “adapting to technical progress”
18. Provision and Use of Work Equipment Regulations 1998 [SI 1998/2306]
20. The use of HIPPS should be addressed within a safety case. Past experience
has indicated that Inspectors should ask generic question(s) during the issues
raised stage of every Safety Case assessment to establish if any pressure
system situated on the installation is protected by remote HIPPS and vice
versa, for example:
21. GASCET 5.1F16 contains guidance for Inspectors undertaking Safety Case
assessment of HIPPS.
INSPECTION
23. Relevant safety case post acceptance inspection topics [PAITs] which have
been identified should be included in the annual inspection plans for the
installation. Those HIPPS which are particularly critical to safety of persons
should be identified for particular attention during inspection visits.
Verification of the suitability of any transport arrangements that have been put
in place to secure timely access to remote HIPPS locations for critical
maintenance and testing.
27. Well CITHPs are likely to reduce over time and eventually may fall to a level
below that of the pipeline/riser pressure rating. It will therefore be necessary
to regularly review HIPPS inspection plan priorities in the light of this fact.
[This should be a consideration for the ALARP demonstration for HIPPS.]
REFERENCES
CONSULTATION
28. This SPC has been prepared by OSD3.5 in conjunction with HID SI3 and
OSD3.4.
ESDV
Subsea
HIPPS Manned
installation
Fig. 1 Subsea wells with subsea HIPPS feeding directly to a manned installation, subsea
pipeline/riser not fully rated.
ESDV
Subsea
NUI
HIPPS
Fig. 2 - Subsea wells with subsea HIPPS feed directly to an NUI, the subsea pipeline/riser is not fully
rated.
Topsides piping fully
rated
ESDV
Riser
Fully Not fully
rated rated
Fig. 3 - Subsea wells feed directly to an NUI. The NUI does not have full flow relief
and the NUI import pipeline is fully rated. The NUI exports to a manned installation
and the NUI export riser and the import riser on the manned platform are not fully
rated.
HIPPS ESDV
ESDV
Not fully
rated
Fig. 4 - Local wells, with flow lines fully rated, feed an NUI and the NUI exports to a
manned platform. The NUI topsides are not fully rated. The NUI does not have full
flow relief. The export pipeline from the NUI and the riser at the manned platform are
not fully rated and are protected by HIPPS on the NUI.
ANNEX B
SYSTEM DESIGN
BACKGROUND
3. The starting point should be an inherently safe design for the pressure
system. Refer to Assessment Principles for Offshore Safety Cases
(APOSC) Principle 21. The inherently safer solution to this problem is
to design the riser, the adjacent fortified section and the associated
bolted joints so that they will not rupture. This can be achieved if the
riser and associated items are fully rated to the maximum pressure that
they can be subjected to.
4. An inherently safe system, i.e. a fully rated system, would normally be
designed in accordance with a recognised code such as BS EN 14161
supported by BS PD 8010-2 with the design pressure above the
maximum wellhead pressure. Adherence to such a code gives
confidence that all of the forces acting on the system have been
considered. Codes tend to be conservative to allow a margin for
uncertainty. A fully rated system does not require a HIPPS.
5. In the event that the inherently safe criterion cannot be justified then,
29. Because of the difficulty and risks associated with personnel access to
the types of remote HIPPS being considered, certain SMS issues are
especially relevant. In particular remote monitoring of operational
performance, demand rate and component failures should be carefully
considered as part of the design. A properly developed strategy should
be in place to cater for severe problems such as transmitter failure,
loss of communications or loss of test facility such as valve position
indication. There may be advantages in employing additional
redundancy so that the fault tolerance criterion continues to be met
under certain fault conditions.
30. Subsea transmitters can be 'tested' only crudely, usually implemented
via the methanol flush of the tapping points, but this does not give a
proper calibration (normally done at 0%, 20%, .. 100% of range, both
rising and falling).
31. Subsea HIPPS valves can be tested to an extent by partial stroking,
but some tests should involve full closure. Leak tests might be
necessary depending on the inventory of the protected system. Where
a remote HIPPS also provides topsides protection to an NUI the
closure time for valves can be critical, i.e. where a HIPPS protects a
downstream system with a small inventory from an upstream system
with a large inventory. An automated regime may be the only practical
way to confirm correct operation. These restrictions should be
considered in the reliability calculations.
32. Any maintenance of a subsea HIPPS is likely to need a remotely
operated vehicle (ROV) or diver intervention. Thus as many
components as reasonable should be diver/ROV replaceable.
Instrument isolation valves should be considered for pressure
transmitters, even though they have a potential for failure.
Fig. 2 Design option summary