HSE Procedures

SUEZ OIL COMPANY Cairo-HSE-P-12

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Plant Modification Procedure

Cairo-HSE-P-12

1.0 Introduction

This procedure is applied to ensure that no modification can adversely affect the integrity of
exiting plant; that all modifications are designed and constructed in compliance with accepted
Engineering Standards, Codes of Practice and Company Procedures; that modified plant is
safe to operate; and that all relevant engineering records, drawings and procedures are kept up
to date.

A modification is defined as any change in construction or operation, which meets any of the
following criteria:

Use of a material of construction different from that specified in the original design.
An installation which adds to, or eliminates from, an existing plant.
Replacement of existing unit/equipment by other constructed to a different design
standards or specifications.
Isolation of any safety system or circuit other than for intervention maintenance.
Any change to a safety-related set point, such as a relief valve setting or ESD system
logic. This need not include minor variations to electrical protection settings or non-
critical instrument ranges when such variation will affect only specified equipment. P-1
to be notified for update records.
Any change in duty or mode of operation of plant or equipment from the original design
specifications.

All modifications will be subject to this procedure, and Field Managers are responsible for
ensuring that no modification is installed prior to receipt of formal approval given by the
completion of section B of a PMC.

The only exception to this rule is that field Managers may give provisional approval to a
modification and commence work up to the point of installation to allow an urgent remedial
action considered vital to either the safety of the plant and field personnel or to maintenance
of production. In such event a Field Manager must notify O-1/O-1D and HSE of the action
immediately and indicate the expected time of completion. Only O-1/O-1D shall authorize
the commissioning of a modification. A PMC must always be issued subsequently within
one week to ensure proper consideration of all technical and safety aspects.

2.0 Scope of Application

This document covers procedures to be followed in design and approval of proposed plant
modifications applicable to all SUCO operations at Cairo and the fields. It includes
activities generated by fields, managed by Cairo Head Office and implemented at the fields.

4.0 Responsibilities

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The Projects Division General Manager has appointed P-20 as the Procedure Owner for
this procedure.

The Procedure Owner is responsible for reviewing this procedure, preparing drafts for
approval and reissue.

The Procedure Owner also maintains a file of potential minor amendments to be collated
into a full review and revision when sufficient changes have occurred to make the issue
practicable.

The Projects Division General Manager arranges an appropriate review of this procedure
review including relevant technical specialists before submission to the Managing Directors
for signature.

4.0 Abbreviations used

ESD Emergency Shutdown.

O-10 Engineering General Manager.
HAZOP Hazard and Operability Study.
HSE Health, Safety & Environment Gen. Mgr.
O-1 Operations General Manager.
O1-D Deputy Operations General Manager.
O-51 Production Manager.
P-1 Engineering & Projects General Manager.
P-10 Planning & Follow Up Assistant General Manager
P-20 Engineering Assistant General Manager
PMC Plant Modification Certificate.
P &ID Piping and Instrumentation Diagram.
SOR Statement of Requirement.
T & HSER Technical and HSE Review.
O-51 Production Manager.

5.0 Procedure

A PMC is divided into six sections, which must be completed in sequence to carry out a
modification from a concept up to necessary approvals, installation and operation. These
sections are to be completed as follows:

5.1 Section A - Operations/HSE

The originator of a concept discusses the matter with relevant field engineers prior to
informal presentation to the Field Manager. It is recommended that the opinions of the
Process/Production / Gas Plant, Maintenance, and HSE Department are sought at this
time.

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The Field Manager, advised by field staff, decides if the concept appears both
operationally desirable and technically feasible, and informs the originator whether the
concept is accepted or rejected.

If the concept is accepted the originator completes Section A.

A1 Description & Outline SOR

The modification is briefly described, with S.O.R to detail the purpose and set
criteria for design. Supporting documents must include a P&ID marked to show
the location. Other documents may be added as required.

A2 Justification

Originator to justify the subject.

A3 Preliminary Cost-Benefit Analysis

A rough cost estimate with benefit analysis to be prepared by the originator. The
originator attaches supporting documents or drawings, signs and passes the PMC
to HSE, Field Engineer.

A4 Operations / HSE Field Technical Review

The field HSE Superintendent reviews the proposal with Process, Production,
Mechanical, Instrument, Electrical and Inspection Engineers. Technical opinions
on the engineering and safety aspects of the proposal shall be considered. All
persons consulted write their comments on a T& HSER form. Specific points
listed below must be considered:

The ability of the modification to perform the function to the criteria set by the
statement of requirements.
Consideration of hazards which could arise during fabrication, installation,
commissioning, and maintenance.
Identification of hazards, which could arise by virtue of upset operation or a
mechanical failure.
Identification of environmental aspects during commissioning, operation and
decommissioning that could have significant environmental impacts.

If the proposal is satisfactorily defined then HSE Supt. Production, Maintenance

sign to indicate completion of the preliminary evaluation and send the PMC with
the T& HSER forms to the Field Manager.

A5 Field Management Approval

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The field Manager signs to indicate site approval & passes the PMC to the
Maintenance Department.

Registration

The Maintenance Department records this in a Field PMC Register, and sends the
PMC to O-1/O-1D.

A6 Operations Cairo Approval

O-51 to obtains a serial number, holds the original PMC and issue stamped and
registered copies to concerned Departments within Operations. O-51 is
responsible for controlling and follow-up the PMC.

O-51 to issue monthly updated status report of PMC to all Field Mgrs. O-51, O-
10 & other concerned Departments review the PMC ensure that the modification
is adequately justified and either accept or reject the proposal.

A7 HSE Cairo Approval

O-51 issues the original PMC to HSE for review and approval.

A8 Operations Management Approval

An accepted / rejected PMC is signed and passed to O-1/O-1D. A rejected PMC

is returned to the Field Manager with a brief note giving the reason for rejection
with copy to HSE. It may be deemed to consult outside specialists for technical
support and hazop review. O-1 and O-1D sign the PMC for approval.

A9 Hand-Over to Engineering & Projects

An approved original PMC is passed to P-1.

O-1/O-1D indicate basic requirements of the proposed PMC for further detailed
technical review and cost benefit analysis.

5.2 Section B - Engineering & Projects

Registration

Eng. & Projects opens a design file under the allocated serial number.

B1 Preliminary Tech-economic review

Eng. & projects reviews the proposed PMC and verifies the preliminary cost-
benefit analysis.

B2 PMC Technical Review

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Eng. & Projects Division develops a design in accordance with

National/International standards and codes of practice.

The preliminary SOR shall be reviewed and a more detailed SOR prepared if
required.
The plant modification shall be reviewed by all technical discipline. The PMC file
shall include all documents, data sheets, calculations, specifications and as-built
drawings.
As-built drawings to be modified by Exploration Division under Projects Division
supervision.
A design file with all necessary documents and drawings must be compiled.
The preliminary cost-benefit analysis shall be reviewed and a more detailed budget
cost estimate and benefits analysis for the plant modification to be prepared if
required.
A preliminary schedule for PMC implementation shall be prepared.

B3 Hazop and other HSE Review

A Hazop review to be conducted if necessary by Projects/Operations /HSE

during engineering phase. Specific points, which must be considered, are:

The ability of the modification to perform the required function to the criteria given
in the SOR.
Consideration of any hazards which could arise during fabrication, installation,
commissioning and maintenance.
Identification of hazards, which could arise by virtue of, upset operation or
mechanical failure.

P-1 will inform O-1/O-1D/HSE by memorandum of any request for outside

specialists for Hazop study.

In addition the expected environmental impacts will be assessed and evaluated

for inclusion in the significant aspects list.

B4 Projects Management approval

P-1 signs for PMC Design file approval

B5 Operations Management approval

O-1/O-1D sign for permission to progress the modification after review of design file
by concerned Field and Cairo Office Department.

5.3 Section C - Financial approval

C1 Budget Proposal

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Concerned Division prepares a budget proposal form based on the estimate given
in section B, and obtains approvals in accordance with company procedures.
PMC processing to be in accordance with Sucos Financial Procedures.

If there is no allowance in the budget, but the modification is vital to either the
operation or safety of production plant or personnel and has not been budgeted, then
concerned Division to seek permission from the Managing Directors to use a
contingency.

C2 Transfer of fund

Concerned Division issuing the PMC prepares a memo to pass the fund to Projects
Division for expenditure.

5.4 Section D - Project Execution

D1 Construction and Installation

Upon/before receiving material at site design package is handed over to P-10 to

arrange for construction phase.

Projects Supt. to ensure that all construction, installation, testing, and pre-
commissioning is completed, and that:

Construction is in accordance with the design accepted International / National

Standards & Codes of practice.
Equipment has been checked for cleanliness and hydrostatic pressure tests have
been completed.
All necessary certification and supporting documents are available at
commencement of pre-commissioning.
Construction drawings are marked up to as-built standards and include details of any
corrective engineering or variations found necessary.
Only minor work is left for completion after commissioning; and that Field Mgr. is
given a detailed punch list B&C category item of such work, a copy of which must
be compiled with the design file.
Special consideration to be given for modifications concerning offshore installation
/connections and hot works which require a dedicated fire-fighting boat. This
matter should be planned and arranged between Operations and Projects General
Managers for right weather window.

D2 Status Reporting

P-1 will prepare a monthly status report on each serial referenced modification.

5.5 Section E - Hand Over/Commissioning

E1 Hand Over and commissioning

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Projects and Operations will agree, early in the project execution, detailed hand-
over and commissioning procedures. Projects Superintendent signs to indicate
that the modification completed and that all pre-commissioning requirements
have been completed.

Field Manager to ensure completion of the following:

The commissioning procedure and operator training are adequate in respect of the
modification.
Commissioning, including all de-spading, leak testing, inerting, and introduction of
process fluids is carried out.
P-1 is advised if any dismantling or rectification work which could affect original
certification was carried out during commissioning.
Making all necessary changes in start-up, Operating, shutdown and Emergency
procedures in the light of commissioning experience.
Providing training or instruction to plant Operators as required.

If commissioning cannot be carried out for any reason, then the copy PMC is
returned to
O-1/O-1D with a Memorandum giving the reason for this inability.

E2 Field/Operations Acceptance Certificate

On completion of the modification an Operations acceptance certificate will be

issued by Projects superintendent & signed by Field Manager to confirm
acceptance of the modification and all related documentation.

Field Manager will pass the original PMC to O-1 for documentation.

5.6 Section F - Post Commissioning

F1 Post-commissioning Health and Safety Review

When the modification is completed and in operation for an agreed period, a post
commissioning review will be undertaken by Operations to evaluate the facility
as an operating unit, including the standards of Operation and Maintenance.
Field Manager will issue a report including evaluation outcome to O-1/O-1D
with copies to P-1 and HSE.

O-51 to ensure that the report and as-built drawings are compiled with the PMC file.

Moreover a copy of as-built drawings to be compiled with the concerned field

operating and maintenance manuals.

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6.0 Applicable Forms

Reference Title
HSE-F-21 Part 1 Plant Modification Certificate.
HSE-F-21 Part 2 Procedure Approval Sheet.

7.0 Applicable Records

All records related to PMCS and relevant correspondence are retained for a minimum of 10
years from commissioning of change.

8.0 Date came into effect

This procedure is effective from 31/01/05.

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Plant Modification Certificate Form Part 1

Serial Reference Number :

A1 Description & Outline Statement of Requirements :

Attachment Reference :

A2 Justification :

Attachment Reference :

A3 Preliminary Cost / Benefit Analysis

Attachment Reference :

Originator Name : Signature Date

A4 Field Technical Approval HSE Prod. Maint. Others

A5 Field Management Approval

A6 Operations / Cairo Approval O-51 O-10 Others

A7 HSE Cairo Approval

A8 Operations Management Approval O-1 O-1D

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Plant Modification Certificate Form Part 2

B1/B2/B3 Technical and Economic Review Signature Date

B4 Engineering & Projects Manager Signature Date

B5 Operations Management Approval Signature Date

SECTION E : Projects Supt. / Field Manager

E2 Operations Acceptance Certificate completed Signature Date

Projects Superintendent Signature Date

Field Manager Signature Date

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Projects Division
Plant Modification Procedure

Modification concept HSE Cairo MDs

Budget If Vital
presentation by Review Allowance
No
To use
Originator &Approval Contingency

Yes

Field Manager Operations

Management Approval Concerned Funds
Concept O-1/O-1D
No
Field Mgr. Approval
Acceptance For Engineering
Study

Yes
Yes

Hand-Over To Transfer of Funds

Description &Outline
Engineering To Projects
SOR Preparation Division
&Projects

Subject Materials
Registration
Justification Purchase

Rough Preliminary
Construction
Cost Estimate Tech/ Economic
&Installation
&Benefit Analysis Review

Yes Modification
Field
Handover
Operations/HSE Technical Review
Technical Review
&Commissioning
&Cost estimate

Hazop Review
Proposal
(If necessary) If
Satisfactorily No O-1/O-1D
By Projects/ Completed
Defined
Opreations/HSE

Yes Yes

Projects Field/Operations
Field Manager
Management Acceptance
Approval Approval P-1 Certificate

Registration by Operations
Post Commissioning
Cairo Production Management
Health &Safety
Approval
Review by Field
O-1/O-1D

Operations
Cairo Budget Proposal
Review & O-1/O-1D
Preparation by
Approval Operations P1/HSE

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