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2010 SPU OMS Gaps

Ranking Matrix
High (5) floderate to High (4) Moderate (3) IMPORTANCE Low to Moderate (2) Low (1)

Low Risk + Low to Efficiency Gaps Moderate (1) (2)

Moderate (3)

Moderate to High (4)

DAL

High (5)
1
OMS gaps V4

GAP RISK TO THE BUSINESS

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El 4.1 Procedures & Practices

2.2 People & Competence 3.1 Risk Assessment 3.3 Process Safety 7.1 Regulatory Compliance

LI 4.2
5.4 Inspection & Maint. 2.5 Working w/Contractors

4.5 Control of Work 4.6 Crisis & Continuity Man &ER 4.4 Incident Management

LI 6.6 ProcurementMmgt & LI 4.3 Information Document Control

6.8 Cl 2.3 Operating Discipline

El 1.3 Planning & Control

1.5 Accountability
DAL OMS gaps V4

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2010 SPU OMS

Gap assessment
Logistics I SPU HSSE 5,5 55 SPU HUB (H) HSSEIEng HSSEIEng HSSEIEng 5,5 45 4,4 HSSE/Eng Subsea Subsea Subsea 3,5 HSSE/Eng HSSE/Eng 5,5 Logistics I Subsea I

Lack of Procedure review and development A lnconsistent methodology in creating & reviewing Operating procedures (HSSE/E 5,5) Procedure creation review orocess not followed (SPU 4.5 No formal process for verifying the use of procedures in the field Lack of culture to use procedures in G0M Update procedures and practices STP development I ETP review and adoption Lack of guidance regarding the creation and review of operating procedures Lack of content around IM Element 6 for procedures specifically maintenance, Norm Ops Lack of clarity on procedural authority to sign off on (Ops, EA, HSSE) Reference drawings and documents attached into procedures are sometimes not updated to As Built Procedure standardization and control Lack of formal I new employee training Lack of repository for documentation for procedural admin (& training & communication) Monitoring & tracking of procedural reviews Need people resourcing strategy A Challenges filling open roles for operations positions (Subsea 5,5) Lack of confidence in plan to ensure competent resources to fill and backfill (Hub MD 4,5) 5,5 5,5
3
.

B c D 4.1 Procedures & Practices E F G H a

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K L

-ISSEIEng Hub (H) Hub (MD) Hub (MD)

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2010 SPU OMS Gap assessment

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HSSE1Eflg.
Subsea HSSEIEng HSSEIEng HSSEIEng HSSE/Eng HSSE/Eng HSSE/Eng HSSEI Eng HSSE/Eng

No comprehensive compliance listing and no process to continuously check regulatory requirement updates for subsea equipment and operations Houston based HSSE Compliance tasks not documented in compliance matrix Limited knowledge of documented process to identify legal and reg requirements outside of HSSE Lack of accountability for identifying regulatory and legal requirements Lack of documentation of accountability for performing the compliance tasks in other areas Lack of clarity on employees roles in regulatory compliance Verification of compliance Not using MoC process for regulatory changes or intro of new Ops controls Incorrect application of federal drinking water regs

5,5
5,5 5,5 5,5 5,5 5,5 5,5 5,5 3,5

B C 7.1
Regulatory

D E F G H

Compliance

4
DAL OMSgapsV4

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2010 SPU OMS Gap assessment 4E1

-I

I
A Lack of information to provide predictive indication of process safety issues. Lack of clear subsea Ops risk Management. Lack of alignment with Asset in risk management Activities associated with hydrocarbon risks are not totally understood by Offshore Staff and Engineering Lack of supportive evidence that HAZOP actions were being tracked to closure Lack of implementation of GP 48-02 HAZOP ETP No Operating Authority for 3.3.1 Lack of understanding of major Hazard Risk Reduction measures and awareness B C D E f

I
5,5 5,5 5,5 5,5 4,5

Subsea HSSE/Eng HSSE/Eng HSSE/Eng SPU SPU Subsea HSSE/Eng Subsea SPU SPU SPU SPU SPU SPU Subsea SPU SPL

3.3 Process Safety

3,5

4.2 MoC

A B A B C D

No robust system for SPOT (Subsea Production Operations Team) specific MOCs; Inconsistent knowledge of bizflow procedures Inconsistent implementation of GoM SPU Risk policy in D&C MoC procedure Existing detailed Subsea equipment MTCE requirements are not linked to a strategy statement (Atlantis Audit) Inspection program gap closure plans not all complete (closed only for marine, mechanical, pressure systems, topside structural). Lack of closure of GP (32-30) gaps Lack of chemical management strategy No formal QAIQC system for system repairs and mods based on inspection findings
-

5,5 3,5 5,5 4, 5 4,5 4,5 5,3

5.4 Inspection & Maintenance

E F G H I J

Excursions beyond the operating envelope are not formally investigated until a pressure relieving device has 5,3 operated or the SOL has been exceeded No long term TAR plan to establish TAR budgets Lack of control over MTCE budgets & no transparency /reporting of maintenance budgets QAIQC re- commissioned equipment No integrated process for documenting Marine Mechanical inspection findings and tracking action closure No inline inspection program in place for G0M owned & operated pipelines
DAL OMS gaps V4

5,3 3,5 3,5 3,5

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2010 SPU OMS Gap assessment

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Lack of standardization I documentation of the process for PSCM tendering that incorporates robust HSSEIEA and process safety Lack of understanding outside of PSCM of construction management & selection process Inconsistent / absent communication of applicable HSSE/EA requirements I specifications of suppliers

5,5 55 55

HSSEIEng HSSE/Eng HSSE/Eng HSSEIEng HSSEIEng HSSEIEng

C D E

Inconsistent? absent communication of applicable HSSE/EA requirements I specifications to contractor staff 5 5 Lack of systematic process to verify contractor employee competency post initial verification Lack of process to confirm contractor embedment of ETPs SOPs and lessons learned 55 55

j I

F G

A Crisis & Continuity Mgmt&ER B A B

Lack of alignment of ERP exercise I drills to major risk scenarios Lack of verification and assurance of competencies for offshore tactical response I IMT ICS positions

5,3
5,3

spu

HSSE/Eng

Reviewing Fire protection and prevention Training OPRA and Detection

-

5,3
-

Hub (HM)

Incident response capability not fully in place

5,3

Subsea
6

DAL

OMS gaps V4

2010 SPU OMS Gap assessment

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4.3 Information management and document control

No central repository of GoM documents Lack of awareness, definition and usage of confidential I restricted documents I info Inconsistent application / utilization of document control procedures Lack of understanding on roles and responsibilities for reviewing and updating documents Lack of document revision clarification for documents outside controlled management system No formal Cl culture or organized process conformance plan delivery requires a culture of Cl
-

5,3 5,3

HSSE/Eng HSSE/Eng

4,4

SPU

A B C A 1.3 Planning and Control B C D E 15 Aou.di... tyLA B

No formal process in place for verifying the use of procedures in the field Need to clarify expectations Need to ensure stop the job culture is fully embedded, track examples and recognize people Training on regulatory requirements I obligations needed for key staff (following gap assessments on understanding of regulations) No activity based planning No resource loaded SPU integrated plan Inconsistent prioritization methodology across the SPU No long term conformance plan Recast AP to include incorporating OMS gap closure as critical design element Employee adhering to financial DOA Accountabilities not clearly written and understood
DAL OMS gaps V4

4,4 4,4 4,4 4,4 4,4 4,4 4,4 4,4 44 4,4

SPU SPU SPU SPU SPU SPU SPU SPU SPU SPU 7