Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 

### Appendix N

H 2 

### S Contingency Plan for M/V Noble DiscovererRevised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 

### THIS PAGE

INTENTIONALLY

LEFT BLANKShell Gulf of Mexico Inc. 1 

# CHUKCHI SEA REGIONAL



# HYDROGEN SULFIDE (H 2 

# S)

CONTINGENCY PLAN



# Shell Gulf of Mexico, Inc.

Exploration Drilling & Evaluation Operations

Rig: Noble DISCOVERER

February 2011Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 2 THIS PAGE INTENTIONALLY LEFT BLANKHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 3 TABLE OF CONTENTS

I. DEFINITIONS 7

II. INTRODUCTION 7

III. OPERATING PHILOSOPHY 8

IV. H 2 S and SO 2 Properties 8 A. Hydrogen Sulfide 8

B. Sulfur Dioxide 11

V. H 2 S TRAINING 14

VI. SAFETY EQUIPMENT 16

A. Muster Areas 16 B. Safe Briefing Areas 16

C. Wind Direction Indications 16 D. Danger Signs 16 E. Operating Condition Signs 17

F. H 2 S Detectors and Alarms 17 G. Flare Line Piping 18

H. H 2 S Service Equipment 19

I. H 2 S Scavengers 19 J. Breathing Air Cascades and Manifolds 19 K. Safety Equipment 20 L. Metallurgical Properties of Equipment 20

M. Fans 21
N. Forced Air Control Switches 21 O. Attending Vessels 21

VII. NORMAL OPERATING PROCEDURES 21 A. Emergency Phone List 21 B. Safety Equipment 22 C. Supplied Air Breathing Equipment 22 D. Training 22 E. Testing 23 F. Reporting Aboard Drillship 23 G. Breathing Air Equipment 23

H. Drills 24 I. Spare Equipment 24 J. Spot Checks 24

K. Wind Direction 24 L. Welding Prohibition 24

VIII. OPERATING CONDITIONS – CLASSIFICATIONS 25Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 4 A. Possible Hazardous Conditions 25

B. Condition I 25

C. Condition II 26

D. Condition III 27

IX. H 2 S EMERGENCY PROCEDURES 28 A. Emergency Procedures for Condition I 28 B. Emergency Procedures for Condition II and III 30

C. Evacuation Procedures 32

X. SPECIAL OPERATIONS 33 A. Other Operations 33 B. Monitor Observation During Specific Operations 33

XI. WELL CONTROL 33 A. Trip Gas 33

B. All Kicks 34

XII. LOST CIRCULATION 34

XIII. PARTIAL EVACUATION PROCEDURE 34

XIV. RESPONSIBILI TIES AND DUTIES – H 2 S 34

A. All Personnel 34 B. Shell Drilling Foreman 34 C. Vessel Master/ Noble Drilling Superintendent 35

D. H 2 S Safety Technicians 36 E. Dispatcher/ Radio Operator 37 F. Noble Toolpusher/ Driller 37 G. Mudlogger 38 H. Mud Engineer 38

I. H 2 S Flaring 38

XV. PROCEDURE FOR INFORM ING PERSONNEL OF THE 39

“H 2 S CONTINGENCY PLAN” A. Aboard Drillship 39 B. Aboard Support Vessels 39

XVI. SEARCH AND RESCUE TEAMS 39 A. Primary Goal 39

B. Critical Areas 39

C. Unconcious Victims 40 D. Purging the Area 40

E. Procedures and Drills 40Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 5 

### APPENDIX 43

SECTION A: Procedures

A-1 Well Control Procedures 44

A-2 Lost Circulation Procedure 46 A-3 Mud Treating 47

SECTION B: General Information

B-1 Toxicity of Various Gases 50 B-1 Properties of Gases 50

B-1 Treatment for H 2 S Poisoning 51

B-1 SO 2 Effects 52 B-1 Contingency Plan Memor andum of Understanding 53 B-2 Breathing Air Equipment Drills for On-Duty Personnel 54 B-3 Breathing Air Equipment Drills for Off-Duty Personnel 56 B-4 Hydrogen Sulfide Training Curriculum and Forms 58

Standard Fit Test Form 60 Training Roster Form 61 B-5 Emergency Telephone Listing 62 B-6 Key Personnel to Remain Aboard During Partial Evacuation 64

SECTION C: Equipment List and Checklists

C-1 H 2 S Equipment List for Rig and Vessels as applicable 65 C-2 Noble Drilling Super intendent Checklist: Safety Equipment 67 C-3 Safety Equipment Checklist- Mudlogger 69 C-4 Safety Equipment Checklist- H 2 S Safety Technician 70 C-5 Safety Equipment Checklist- Mud Engineer 71

C-6 Shell Checklist of Routine Duties 72

SECTION D: Rules and Regulations

D-1 30 CFR 250-490 Hydrogen Sulf ide Regulations 73
D-2 MMS PINC list for H 2 S 87

D-3 29 CFR - CHAPTER XVII - PART 1910.134 Respiratory Protecti on 114

SECTION E: Rig Drawings 164

94731-341-001 GAS DETECTION ONE LINE

94731-345-001 BREATHING AIR ONE LINE 1 OF 2

94731-345-002 BREATHING AIR ONE LINE 2 OF 2
94731-345-003 QUARTERS MAIN DECK EQUIPMENT LAYOUT
94731-345-004 QUARTERS POOP DECK EQUIPMENT LAYOUTHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 6 94731-345-005 QUARTERS BOAT DECK EQUIPMENT LAYOUT
94731-345-006 QUARTERS BRIDGE DECK EQUIPMENT LAYOUT
94731-345-007 QUARTERS/BRIDGE DECK EQUIPMENT LAYOUT

94731-345-008 HOUSE TOP EQUIPMENT LAYOUT

94731-345-009 FORWARD BRIDGE EQUIPMENT LAYOUT

94731-345-010 MAIN DECK BO W EQUIPMENT LAYOUT

94731-345-011 DRILL FLOOR EQUIPMENT LAYOUT

94731-345-012 SHAKERS EQ UIPMENT LAYOUT

94731-345-013 CEMENT UNIT & MOON POOL EQUIPMENT

LAYOUT

94731-345-014 SACK ROOM, PU MP ROOM & MUD PIT
EQUIPMENT LAYOUT

94731-345-015 SCR & ENGINE RO OM EQUIPMENT LAYOUT

94731-345-016 CRANES EQ UIPMENT LAYOUTHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 7 I. DEFINITIONS

 Bureau of Ocean Energy Management, R egulation and Enforcement (BOEMRE or BOE)-formerly the Miner als Management Service (MMS)

 H 2 S Absent- previous drilli ng, testing, logging and sa mpling in the area or in equivalent stratigraphic units hav e confirmed the absence of H 2 S in the area to

be drilled

 H 2 S Present- previous drilling, testing, logging and sampling have confirmed the presence of H 2 S in concentrations and volumes that could potentially result in atmospheric concentrations of 20 ppm or more of H 2 S

 H 2 S Unknown- the designation of a zone or geologic formation where neither the presence nor absence of H 2 S has been confirmed

 Application for Permit to Drill (APD)- forms and supporting information, including a request for a classification of an area with respect to H 2 S (absent, present or unknown), submitted to the BO E in advance of the initiation of drilling operations.

 Request for classification- a letter cont aining additional data indicating that a

different H 2 S classification is required to replac e the original classification made by the BOE from data filed with the APD.

 H 2 S Contingency Plan- a set of procedures and practice s submitted to the BOE Regional Supervisor Field Oper ations (RS/FO) prior to t he initiation of operations outlining steps to deal with H 2 S hazards in H 2 S Present or H 2 S Unknown

classified areas.

II. INTRODUCTION

This plan was developed because of the pot ential hazards involved when performing operations in formations that may contain H 2 S. It was written in compliance with the rules and regulations of the BO E in Section 30, Code of F ederal Regulations, Part 250, Subpart 490. This plan specifies precautionary meas ures, safety equipment, emergency procedures, responsibil ities, and duties pertaining to drilling operations in potential H 2 S- bearing formations.

There will be one evacuation vessel (t o be determined) stationed near the M/V Noble

Discoverer ( Discoverer) at all times. The attending evacuation vessel will be equipped with a breathing air cascade system and an H 2 S detection/alarm system. Specific evacuation procedures are discussed in Section IX, H 2 S Emergency Procedures.

To be effective, this plan requires the cooperation and effort of each individual participating in drilli ng operations in a well with the potential of releasing H 2 S. Each

individual should know his/her responsibilities and duties in regard to normal operations and emergency procedures. Personnel should thoroughly understand and be able to use, at a moment’s notice, all safety equipment on board the rig. They should

familiarize themselves with the location of all safety equipment and see that their individually assigned equipment is properly st ored, easily accessi ble, and routinely maintained. The ideas and suggestions of each individual involved in the drilling orHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 8 abandonment of a potential sour gas well are highly we lcomed and are an asset for providing the safest working conditions possible.

This H 2 S Contingency Plan will go in to effect upon entering the Chukchi Sea. Safety equipment will be installed on the vessel and will be functi onal and tested prior to departure from Dutch Harbor. Personnel will be trained and co mpetent to carry out the provisions of the plan.

Shell Gulf of Mexico, Inc. (Shell) intends to make every effort to provide adequate safeguards against harm to persons both on loca tion and in the immediate vicinity from the effects of hydrogen sulfide if re leased into the atmosphere.

III. OPERATING PHILOSOPHY

Formations in the Chukchi Sea may or may not contain H 2 S. The BOEMRE, in keeping with the provisions of 30 CFR 250.490, has classified the Chukchi Sea as H 2 S

UNKNOWN.

Shell is taking every precaution to protect the people and the environm ent in the unlikely

event that H 2 S is encountered. The Discoverer will be fitted with a ll of the equipment and safety devices as required by code and all personnel who will be onboard the vessel during the drilling wells in the Chukchi Sea will be properly trained and drilled as required by code.

IV. H 2 S and SO 2 Properties

A. HYDROGEN SULFIDE 1. Physical Properties

CHEMICAL NAME Hydrogen Sulfide

CAS NUMBER 7783-06-4

SYNONYMS Sulfurated hydr ogen, hydrosulfuric acid, dihydrogen sulfide CHEMICAL FAMILY Inorganic sulfide

CHEMICAL FORMULA H 2 S

NORMAL PHYSICAL

STATE Colorless gas, vapor densit y at 59oF (15oC) at 1 atmosphere = 1.1895 SG

IGNITION

TEMPERATURE 500oF (260oC)

BOILING POINT -76oF (-60.2oC) MELTING POINT -117.2oF (-82.9oC) FLAMMABLE LIMITS 4.3 - 46% by volume in air

SOLUBILITY Soluble in water and oil; solubility decreases as the fluid temperature increases.

COMBUSTIBILITY Burns with a blue fl ame to produce sulfur dioxide.

WARNING

PROPERTIES H 2 S has an extremely unpleasant odor, similar to the smell of rotten eggs, and is easily detected at low concentrationsHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 9 (0.13 ppm). Due to the paralyzing effect the gas has on the olfactory nerve, THE SENSE OF SMELL IS NOT AN

ACCEPTABLE INDICATOR.

2. Exposure Limits

The Occupational Safety and Health Administration (OSHA) permissible exposure limit (PEL) for H 2 S is 10 ppm for eight-hour time-weighted average (TWA 8 ) or 15 ppm for short term exposure limit (STEL) as averaged over 15 minutes, per 29 CF R Part 1910.1000, “Toxic and Hazardous Substance,” U.S. Departm ent of Labor, Occupational Safety and Health Administration. Recently, the American Conference of Governmental Industrial Hygienists (ACGIH) reduced their recommended exposure limits for H 2 S. ACGIH voted to reduce the 8-hour time-weighted average Threshold Limit Value (TLV-TWA 8 ) for H 2 S from 10 to 1 ppm and their Short Term Exposure Limit (T LV-STEL) from 15 to 5 ppm. ACGIH TLVs reflect industry consensus on the level of exposure a typical worker can experience without unreasonable risk of disease or injury. These limits are voluntary standards and are not enforceable where OSHA’s PELs and regulatory concentration limits are. Most currently available H 2 S measuring and monitoring equipment is not accurate in the 1 ppm range. The National Institute for Safety and Health (NIOSH) considers a concentration of 100 ppm H 2 S to be immediately dangerous to life and health (IDLH). For purposes of this contingency plan, the concentration
values listed in 30 CFR 250.490 wi ll be used for detection, alarm and

action limits.

3. Physiological Effects

When a person inhales H 2 S, the gas goes directly through the lungs and almost instantaneously into the bloodstream. Through an oxidation reaction, H 2 S is broken down in the body into a harmless compound. However, if the individual br eathes in large quantities of H 2 S, the oxidation process lags behind the intake rate of the gas. The unoxidized H 2 S builds up in the blood and the indi vidual becomes poisoned. The nerve center in the brain which controls breathing is paralyzed and the re spiration process is halted. Death is caused by asphyxiation at the cellular level.

Susceptibility to H 2 S poisoning is dependent on four factors:

 Duration: The length of time the indivi dual is exposed to non-lethal

concentrations of H 2 S. Longer exposure to low H 2 S concentrations has a desensitizing effect on the sense of smell.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 10  Frequency: How often the individual is exposed to H 2 S. Closely repeated shortterm exposures at low concentrations may lead to chronic irritation of the eyes, nose and throat an d headaches, dizziness and upset

stomach. Even at concentrations under 5 ppm, metabolic changes and increased anxiety have been reported in people who are exercising.

 Intensity: The concentration of the exposure . The higher the concentration, the greater the ph ysiological effect.

 Individual Susceptibility: Dependent on the individual’s physi ological make-up. Studies show that symptoms of H 2 S exposure vary considerably because of individual physiological make-up. Personnel may be highly susceptible to H 2 S due to health reasons such as lung diseases,

and the individual’s mental stat e such as anxiety attacks.

4. H 2 S Toxicity Table The following table shows approximate values for guidance.

CONCENTRATIONS OF H 2 S IN AIR

% by

Volume ppm by

Volume Grains per

100 std.

cubic feet Milligrams per cubic

meter Typical Characteristics Regarding H 2 S Exposure

0.000013 0.13 0.008 0.18 Obvi ous and unpleasant odor generally at 0.13 ppm and quite noticeable at 4.6 ppm. As the concentration increases, the sense of smell fatigues and the gas can no longer be detected by odor. Often

referred to as the Lower Odor

Threshold level. 0.001 10 0.63 14.41 Unpleasant odor. Possible eye
irritation. OSHA PEL-TWA 8 (see 29 CFR Part 1919.1000, Table Z-1A)

0.0015 15 0-94 21.61 OSHA STEL averaged over 15 min. 0.002 20 1.26 28.83 Burning sensation in eyes and irritation of the resp iratory tract after one hour or more of exposure. BOE requires audio and visual alarms and other safety measures to be employed

when H 2 S is present at or above this concentration (30 CFR 250.490).Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 11 0.005 50 3.15 72.07 Loss of sens e of smell after about 15

or more minutes ex posure. Exposure over one hour may lead to headache, dizziness, and or staggering. Pulmonary edema has been reported following extended exposure to greater than 50 ppm. Exposure at 50 ppm or greater can cause serious eye irritation or damage.

0.01 100 6.3 144.14 C oughing, eye irritation, loss of sense

of smell after 3-5 minutes. Altered respiration, pain in the eyes, and drowsiness after about 15-20 minutes, followed by throat irritation after one hour. Upper odor threshold. Prolonged exposure results in an increase in the severity of these symptoms. Concent ration considered by NIOSH to be IDLH ( See “NIOSH Pocket Guide to Chemical Hazards”, 5th edition.)

0.03 300 18.9 432.4 Maximum c oncentration from which one could escape within 30 minutes, without experiencing impairing or

irreversible health effects if not breathing supplied air.

0.05 500 31.49 720.49 Unconsciousness after short exposure, cessation of breathing if not treated quickly. Dizziness, loss of sense of reasoning and balance. Victim will probab ly need prompt cardiopulmonary resuscitation (CPR).

0.07 700 44.08 1008.55 Unconsciou s quickly. Breathing will stop and death will result if not rescued promptly. Artificial ventilation and/or CPR needed immediately.

0.10 1000 62.98 1400.98 Unconsci ous at once. Permanent brain damage or death may result. Rescue promptly and apply artificial

ventilation and/or CPR.

B. SULFUR DIOXIDE

One method by which Sulfur Dioxide (SO 2 ) is formed can be the result of burning H 2 S. SO 2 is a colorless, non-flamm able gas, having a pungent odorHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 12 and characterized by an acid taste at very low concentrations. SO 2 in concentrations of 3-5 ppm in air is an in tense irritant to humans and therefore readily detectable.

1. Physical Properties

CHEMICAL NAME Sulfur Dioxide

CAS NUMBER 7446-09-05

SYNONYMS Sulfurous Anhydr ide, Sulfurous Oxide

CHEMICAL FAMILY Inorganic

CHEMICAL FORMULA SO 2

NORMAL PHYSICAL STATE Colorless gas appreciably heavier than air. Vapor density at 32oF (0oC) and 1 atmosphere = 2.26 SG

BOILING POINT 14oF (-10.0oC)

FLAMMABLE LIMITS Non-flammable

SOLUBILITY Readily soluble in water and oil; solubility decreases as the fluid temperature increases.

ODOR AND WARNING

PROPERTIES Sulfur dioxide has a pungent odor associated with burning sulfur.

2. Exposure Limits

The OSHA established the PEL-TWA 8 for SO 2 at 2 ppm, or the STEL of 5 ppm as averaged over 15 minutes (see 29 CFR Part 1910.1000). ACGIH recommends 2 ppm as the TWA 8 for SO 2

.

3. Physiological Effects

 Acute Toxicity:

Inhalation at certain concentrations can lead to irritation, injury or death. Exposure at 50 ppm rapidly causes irritation to the mucous

membranes of the nose and thr oat, coughing, reflex bronchiconstriction, and breathing congestion as the SO 2 oxidizes and hydrolyzes to sulfuric acid (H 2 SO 4 ). This SO 2 concentration will not be tolerated by most persons for more than 15 minutes. The severely irritating effect of the ga s makes it unlikely that any person would be able to voluntarily remain in a contaminated atmosphere for long periods. The most comm on cause of sulfur dioxide poisoning occurs when a person is either unc onscious or trapped and unable to move. Acute reactions to exposure to high concentrations are conjunctivitis, nausea, vomiting, abdominal pain, and sore throat followed by bronchitis, pneumonia and/or complaints of weakness for a period of weeks.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 13  Chronic Toxicity: Reports indicated that prolonged exposures to SO 2 may contribute

to alterations in the sense of sm ell and taste, shortness of breath on exertion, and a higher frequency of respiratory infections compared to unexposed persons. SO 2 in the work environment may “possibly” enhance the sus pected carcinogenic effect of arsenic and other cancer agents.

4. SO 2 Toxicity Table

NOTE: Any pre-existing chronic r espiratory impairment must be considered in regard to job placement since these conditions can be aggravated by exposure to sulfur dioxide.

CONCENTRATIONS OF SO 2 IN AIR

% by

Volume PPM by

Volume Grains per

100 std.

cubic feet Milligrams per cubic

meter Typical Characteristics Regarding SO 2 Exposure

0.0001 1 0.012 2.71 Pungent odor, may cause respiratory changes

0.002 2 0.24 5.42 OSHA PEL-TWA 8 (see 29 CFR Part 1910.1000, Table Z-1A) and ACGIH

recommended TLV. 0.0005 5 0.59 13.50 Burning eyes, breathing irritation and minor throat irritation. OSHA STEL averaged over 15 minutes (see 29 CFR Part 1910.1000, Table Z-1A).
0.0012 12 1.42 32.49 Throat irritation, cough, constriction in chest, watering eyes, and nausea.

0.010 100 12.00 271.00 This is t he maximum concentration from which one could escape within 30 minutes, without experiencing impairing or irreversible health effects without supplied breathing air. Concentration considered IDLH (see “NIOSH Pocket Guide to Chemical Hazards”, 5th edition).

0.015 150 17.76 406.35 Extrem e irritation. Can be tolerated for only a

few minutes.

0.05 500 59.2 1354.50 Causes a sense of suffocation, even with the first breath. Rescue promptly and apply

artificial ventilation and/or CPR. 0.10 1000 118.4 2708.99 Death may resu lt unless rescued promptly. Apply artificial ventilation and/or (CPR) immediately.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 14 V. H 2 S TRAINING

At the docks and on the Discoverer ; each individual will be as ked if they have been cleared by a physician to use a respirator. This requirement will be the responsibility of each company or individual bef ore coming aboard the drillship.

Each person will be informed on the restrict ions of having beards and wearing contact lenses. They will also be informed of the availability of spectacle kits.

The safety program is outlined in the H 2 S Contingency Plan. This plan will be available on the rig. Each indivi dual will be brie fed on the H 2 S Contingency Plan and sign the

“ Contingency Plan Memor andum of Understanding ”.

After the H 2 S equipment is rigged up, all personnel will be H 2 S trained and put through a drill. Any deficiencies will be corrected.

Training Completion cards are good for one year and will indicate date of training completion or expiration. Personnel previo usly trained on another facility and visiting

the Discoverer must attend a “supplemental briefing” on H 2 S equipment and procedures before beginning duty. Vi sitors without current H 2 S certification who remain on the facility more than 24 hours must receive full H 2 S training given all crew members. A “supplemental briefing” will incl ude but not be limited to the location, use and donning of an assigned respirator, familiarization with safe briefing areas, alarms with instruction on responsibilities in the event of a release and hazards of H 2 S and SO 2

.

Topics for full H 2 S training shall include, but not limited to the following:

A. Brief Introduction of H 2 S

1. Slide or VCR present ation (If available)

2. H 2 S Material will be distributed

3. Re-emphasize the properties , toxicity, and hazards of H 2 S

4. Source of SO 2

B. H 2 S Detection

1. Description and sensitivity of H 2 S sensors

2. Description of warning system (how it works and its location)

3. Actual location of H 2 S sensors

4. Instruction on use of pump type detector

5. Use of card detectors , ampoules, or dosimeters

6. Use of combustible gas detector

7. Other personnel detectors

8. Alarm conditions I, II or III (10 ppm, 20 ppm or 50 ppm)Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 15 9. SO 2 (2 ppm and 5 ppm)

C. H 2 S Protection

1. Types of breathing apparatus pr ovided (30-minute SCBA & SKA PAK with voice diaphragms for communication)

2. Principle of how br eathing apparatus works

3. Demonstration on how to use breathing apparatus

4. Location of breathing apparatus

D. Cascade System

1. Description of a typical cascade system

2. How the system works

3. Cascade locations on the drillship with reference to briefing areas

4. How to use cascade system (with SKA PAKS & refill)

5. Importance of wind direction and location of windsocks

6. Purpose of compressor/function

E. H 2 S Rescue and First Aid

1. Importance of wind direction

2. Safe briefing area

3. “Buddy” System

4. H 2 S symptoms

5. Methods of rescue

F. Hands on Training

1. Donning/familiarization of SCBA

2. Donning/familiarization of Escape/Work unit

3. Familiarizat ion with cascades

4. Use of O 2 resuscitator

5. Alarm conditions – upwind briefing areas, etc.

6. Duties and responsibili ties of all personnel

7. Procedures for evacuation

8. Search and Rescue teams

G. Certification

A. Testing on material coveredHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 16 VI. SAFETY EQUIPMENT

A summary of procedures and equipment that will be operational at compliance depth is

as follows:

A. Muster Areas

The AFT Muster area will be in the Galley. The FW D Muster area will be in the Forward Foyer which is located in the bow area of t he ship. Personnel AFT of the moonpool will use the AFT Muster area; personnel FWD of the moonpool will use the FWD Muster area.

B. Safe Briefing Areas

Two areas will be designated as “SAFE BRIEFING AREAS” . The AFT Briefing

Area will be located on the AFT Main Deck below the Helicopter Deck. The FWD Briefing Area will be located on the Main Deck Bow. Personnel AFT of the moonpool will use the AFT Briefing Area; personn el FWD of the moonpool will use the FWD Briefing Area. Drawings of t he rig are included in the Appendix.

C. Wind Direction Indicators

Windsocks will be installed on the vessel. They will be posit ioned as to be seen from any location on the ma in deck, rig floor and heliport.

D. Danger Signs

Four 4’ x 8’ danger signs will be displayed from all sides of the vessel in a

manner visible to watercraft and aircra ft. The signs will be yellow with the following warning painted in 12” high black, block lettering.

DANGER POISONOUS GAS

HYDROGEN SULFIDE

DO NOT APPROACH IF RED LIGHTS ARE FLASHING

Signs are worded as per t he regulation. Signs are photo luminescent. The danger signs will be displayed at compliance depth. If the H 2 S concentration exceeds 20 ppm at the surface, four 2’ x 3’ red light panels will be flashing visible to marine traffic, aircraft & personnel on the drillship. Red flags will not be used; red lights will. All signs will be illuminated under conditions of poor visibility and at night. Signs will be posted indicating the safe briefing areas and Condition I, II and III signals, as designated in Section B-1 of the Appendix.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 17 E. Operating Condition Signs

Operating Condition posters indicating C ondition I, II, and III will be located in the following areas:

1. Each level of the living quarters

2. Rig floor

3. Mud pit area

4. Engine room area

5. Work areas on the Main Deck

6. Mud pump area

7. Galley

8. Moonpool

9. Transit room

10. Recreation room

11. Shale shaker

F. H 2 S Detectors and Alarms

The gas detection control panel will be located in the Emergency Response Room. Annunciator panels will be located in the following locations:

1. Company representative office

2. Toolpusher’s office

3. Toolpusher’s quarters

Continuous monitoring type H 2 S detectors, capable of sensing a minimum of 10 ppm H 2 S in air, will be located at each of the following points:

1. Rig floor/ Driller’s station

2. Rig floor/ bell nipple

3. Mud return line/ gumbo box

4. Trip tank

5. Shale shaker 1

6. Shale shaker 2

7. Possum Belly

8. Active pit

9. Pump room

10. Sack roomHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 18 11. Cement unit/Dive control area

12. Bridge Intake

13. Aft Quarters

14. Forward Quarters

15. Quarters Intake HVAC

16. Moonpool

17. Engine room intake

All detectors will be tested once every 24 hours. If te sts are not within 2 ppm or 10 percent, whichever is greater, t hen that sensor wil l be recalibrated.

Automatic H 2 S Alarms (Visible and Audible) will be located at the following points:

1. Rig floor

2. Sack room

3. Active pit

4. Shaker area

5. Pump room

6. Engine room

7. Cement unit /Dive control area

8. Mud logging unit

9. Navigation Bridge Deck (2)

10. Quarters Bridge Deck (3)

11. Quarters Boat Deck (2)

12. Quarters Poop Deck (2)

13. Quarters Main Deck (2)

Alarms will be suitable for the electrical classification of the area where they

are installed. An alarm station will be located in the control house. Upon verification of the alarm, the ship ’s gas alarm system will be engaged.

G. Flare Line Piping

Prior to compliance depth, the degasse r and the mud-gas separator will be rigged so the gas can be flared if H 2 S is encountered in concentrations equal to, or exceeding, 20 ppm. A remote elec tronic ignition device will be available along with an alternate backup method fo r igniting the flare (handheld flare gun). The Flare outlet must be a diameter that allows easy non-restricted flowHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 19 of gas. SO 2 monitor readings will be taken usi ng a portable instrument on an hourly basis and logged in reports.

Blowout Prevention Equipment- The blow out preventers, integral choke and kill lines, and surface manifold are designed for H 2 S service in case it becomes necessary to circulate a kick.

H. H 2 S Service Equipment

N/A (Refer to 30 CFR 250.490 (p) which specifies that this equipment is required for areas classified as “H 2 S PRESENT” or “H 2 S UNKNOWN”)

I. H 2 S Scavengers

A supply of zinc oxide, or an equival ent, will be stored aboard the rig in case

the mud becomes co ntaminated with H 2 S. A detailed m ud treating procedure is given in Section A-3 of the Appendix. After reaching compliance depth, a

sufficient volume of zinc oxide will be maintained aboard the rig to treat the entire system twice with two pounds per barrel (ppb). If water-based drilling

fluids are used and ambient air sensors detect H 2 S either the Garrett-GasTrain test or comparable test for so luble sulfides must immediately be conducted to confirm the presence of H 2 S.

J. Breathing Air Cascade System ( BACS) consists of the following:

1. Grade D/E breathing air compressor

2. Breathing air cascade storage cylinders

3. Interconnection and distribution hose or tubing

4. Distribution panels

5. Manifolds

The BACS utilizes central storage ca scade cylinders and a closed loop high pressure cascade to supply breathing ai r to the distribution panels located

about the vessel. Distributi on panels reduce the high pressure air to working pressure for distributi on to the manifolds.

1. Safe Briefing Areas, Forward and A ft (12 ea. 12-outlet and one 6-outlet)

2. Shale shaker ar ea (2 ea. 3-outlet)

3. Drill floor (2 ea.12-outlet) and 2 ea. 8-cylinder cascades

4. Derrick (3-outlet)

5. Racking cabin (3-outlet)

6. Pump room (6-outlet)

7. Pit room (6-outlet)Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 20 8. Sack room (6-outlet)

9. Mud logging unit (6-outlet)

10. Moon Pool (6-outlet)

11. Bridge (6-outlet)

12. Dive Deck Location (6-outlet)

13. Dive Control Van (6-outlet)

14. Dive Launch & Recovery System (LARS) (6-outlet)

There will also be a breathi ng air cascade system located on a standby vessel to support an evacuation of all personnel aboard the Discoverer and vessel crew aboard the standby vessel. The ve ssel will make optimum use of staying upwind during H 2 S operations. Breathing air co mpressors will be located near the Briefing Areas for refill. All 444 ft 3 (cu ft) breathing air cylinders will be labeled: Safe Breathing Air; Grade D/E Breathing Compressed Air for Human

Use.

K. Safety Equipment

Chalkboards and/or notepads for communi cation are located on the rig floor, shale shaker area, the cement room, and the pump room. Bullhorn, safety litter, first aid kits, re suscitators, safety harnesses and voice transmission devices will be kept in t he ship’s infirmary and/or She ll’s gang box. The list of safety equipment (including breath ing air equipment, resuscitators, H 2 S and

SO 2 detectors, and explosion meters, flare guns, etc.) are listed in Section C of the Appendix.

L. Metallurgical Properties of Equipment

N/A (Refer to 30 CFR 250.490 (p) which specifies that this equipment is required for areas classified as “H 2 S PRESENT” or “ H 2 S UNKNOWN”)

When operating in a zone with H 2 S present, equipment will be used that is constructed of materials with metallurgic al properties that resist or prevent sulfide stress cracking, chloride stre ss cracking, hydrogen-induced cracking and other failure modes. The following will be in effect:

 Tubulars and other equipment, casing, tubing, drill pipe, couplings, flanges, and related equipment should be designed for H 2 S service.

 Temporary downhole well security dev ices such as retrievable packers and bridge plugs should be designed for H 2 S service.

 Wireline lubricators, which may be exposed to fluids containing H 2 S,

must be of H 2 S-resistant materials.

 H 2 S-resistant materials will be used for all elastomer seals.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 21  Deck drains must be equi pped with traps or simila r devices to prevent the escape of H 2 S gas into the atmosphere.

 Precautions will be taken to elimi nate sealed voids in piping designs, such as slip on flanges, reinfo rcing pads, which can be invaded by atomic hydrogen when H 2 S is present.

M. Fans

Movable ventilation devices will be provid ed in work areas. Devices will be capable of dispersing H 2 S or SO 2 vapors away from working personnel. Areas may include rig floor, mud pit, shale shake, and cement unit areas. All

ventilation devices w ill be explosion proof.

N. Forced Air Control Switch

All forced air systems will be shut down upon detection of 20 ppm or greater (mud logging unit, quarters, and any other forced air control switches should be shut off.)

O. Attending Vessels

Vessels that are stationed overnight alongside the Discoverer will be equipped with an H 2 S detection system that acti vates audible and visual

alarms when the concentration of H 2 S in the atmosphere reaches 20 ppm. This requirement does not app ly to vessels that are not stationed alongside overnight or to vessels positioned upwind and at a safe distance from the facility in accordance with the positioni ng procedure described in the approved

H 2 S Contingency Plan.

Attending vessels will be identified pr ior to the commencement of drilling operations and listed in an updated contingency plan. Time along side the

Discoverer will be in compliance with the Air Permit issued by the Environmental Protection Agency.

VII. NORMAL OPERATING PROCEDURES

A. Emergency Phone List

Lists of emergency phone numbers will be sent to the drillship and should be posted at the following locations: Emergency Room, Radio Room, Drillship Master’s office, Noble Drilling Superint endent’s office, Shel l Drilling Foreman’s office, Shell SIMOPS Coordinator’s offi ce and all Support Ve ssels. Copies will

be available in the Shell and Noble An chorage and Houston offices as well.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 22 B. Safety Equipment

All safety equipment and H 2 S related hardware must be set up as outlined

under Section V “Safety Equipment”. All safety equipment must be inspected routinely, paying particular attenti on to resuscitators and breathing air equipment. SCBAs will be pressure- demand-type with hoseline capability

rated for at least 30 minute duration.

C. Supplied Air Breathing Equipment

All personnel on board will be assigned breathing air equipment and, if needed, lead-acetate spot check. Shell and rig contractor personnel required to work in the following areas will be provided with work/escape type air line equipment with 10-minute escape duration. These units ar e in addition to their assigned 30-minute rated units.

1. Rig floor

2. Mud pit area

3. Mud pump room

4. Sack storage area

5. Cementing area

6. Engine room

7. Shale shaker area

8. Mud logging unit

9. Dive Launch and Recovery System (LARS)

10. Dive control van

11. Decompression chamber

12. Dive deck work area

13. Bridge

D. Training

Prior to the initiation of drilling operations, all perso nnel must be thoroughly trained in the use of breathing ai r equipment, emergency procedures, responsibilities, and first aid for H 2 S victims. All personnel when coming on board will immediately receive H 2 S training or a supplemental briefing. The

H 2 S Safety Technician must keep a list of all who have been through the special training program s on board the rig.

Documentation of training must be pr ovided by the service company. All personnel will be briefed on the Contingency Plan and sign a copy of the

“ Contingency Plan Memorandum of Understanding ”, in Section B-1 of theHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 23 Appendix. This document summarizes the steps to be taken during the three conditions under which the drillship may operate. It lists general information about toxic gases, explains t he physiological effects of H 2 S, operating

conditions as defined by the H 2 S contingency plan, and informs each reader of his general responsibilities concer ning safety equipment and emergency procedures.

E. Testing

Below compliance depth the H 2 S detection system will be tested every 24

hours under normal conditions. The H 2 S detectors will be calibrated weekly. In

the event that H 2 S is detected, or when dr illing a zone containing H 2 S, the units will be tested at least once every 24 hours. The time and results of each

test or calibration wi ll be logged by the H 2 S Technician and reported each day

to the Shell Drilling Foreman. The Shell Drill ing Foreman will ensure that the

H 2 S detection equipment calibrations an d tests are recorded on the IADC Daily Drilling Report Form and Morning Report. In the event that an H 2 S

detector does not test successful ly, operations will cease until:

 The detector is repaired

 Approval to proceed is received from the Shell Drilling Foreman, as per
the 30 CFR 250.490.

F. Reporting Aboard the Drillship

When boarding the vessel from either boat or helicopter , all personnel, without exception, must proceed directly to the H 2 S Safety Technician for assignment of breathing air equipment and, if needed, ampoules or equivalent H 2 S

detector. An instruction and orientati on briefing will also be held, if needed (See section on training requirements). The H 2 S Safety Technician will be responsible for assigning equipment to t he individuals and instructing them in

its use.

G. Breathing Air Equipment

Each person aboard the drillshi p will be instructed in t he use of breathing air equipment until supervisory personnel are satisfied t hat each is capable of using the equipment. The training must include all additional personnel that are allowed aboard the drillship during drilling operations.

After familiarization, each on-duty ri g and roustabout crew must perform a weekly drill with breathing equipment. The drill will include such topics as securing the breathing air equipment, pu tting it on, and working for a short period, doffing the equipment, cleaning and storing it for future use. A record should be kept of the crews dr illed and the date. A complete “ BREATHING
AIR EQUIPMENT DRILL ” procedure is given in Section B-2 of Appendix.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 24 H. Drills

Along with normal weekly fire drills a nd safety meetings, weekly breathing air equipment drills and H 2 S training sessions must be held for all personnel and a record of attendance must be kept. Visitors will be given a supplemental briefing even if t hey hold a valid H 2 S card. However, if the visitor stays more than 24 hours, then full H 2 S briefing and orientation wil l be required for the visitor. An explanation of these drills and training sess ions and a list of what they include are provided in Section B-3 of the Appendix.

I. Spare Equipment

Rig crews and service company personnel should be aware of the location of spare breathing air bottles, resusci tation equipment, portable fire extinguishers, and H 2 S detectors. Knowledge of the location of H 2 S detector monitors is vital to understanding the “e mergency conditions”. In addition, key personnel must be trained in the use of the resuscitator and H 2 S detector ampoules.

J. Spot Checks

H 2 S spot checks shall be available for use by working personnel. After H 2 S has been initially detected by any device, periodic inspections of all areas of poor ventilation shall be made with a portable H 2 S detector instrument.

K. Wind Direction

All personnel on the location shall bec ome “wind conscious” and must be

aware of the direction of the prevailing winds at all times. They should

remember that H 2 S is heavier than air and will collect in low places in still air.

The Discoverer has a turret system which enables it to maintain a position with the bow into wind/seas as needed, so wind direction for the most part will run

from forward to aft.

Therefore, the primary Sa fe Briefing Area will be fo rward of the moonpool. Personnel will report to the closest Safe Briefing Area. Personnel forward of the moonpool will report to the forwar d Safe Briefing Area and personnel aft of the moonpool will report to the aft Safe Briefing Area. Should an evacuation become necessary, procedures for evacuation are outlined in Section IX, H 2 S Emergency Procedures.

L. Welding Prohibition

There should be no welding, if H 2 S is detected at the surface, until the surrounding air is thoroughly tested wit h combustible gas and handheld H 2 S meter(s).Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 25 VIII. OPERATING CONDITIONS-Classifications

A. Possible Hazardous Conditions (H 2 S Not Present)

1. Warning Signs: None

2. Alarm: None

3. Characterized By: Routine drilling operations unde r control in zones that

are classified as “H 2 S present” or ”H 2 S unknown”. This condition will be in effect continuously from the base of t he structural casing (as described in the APD) to total depth unless it is nece ssary to go to a C ondition I, II, or

III.

4. General Action:

a. HSE Technicians and H 2 S technicians monitor H 2 S concentrations using the fixed gas detection system

b. Be alert for a condition change
c. Keep all safety equipment available and monitors functioning properly

B. Condition I : Potential Danger ( H 2 S Present ≥ 10 ppm but < 20 ppm)

1. Warning Sign:

“DANGER – POISONOUS GAS - HY DROGEN SULFIDE – DO NOT

APPROACH IF RED LIGHTS ARE FLASHI NG” signs will be displayed on all sides of drillship (yellow with bla ck lettering to be illuminated at night) and under conditions of poor visibility.

2. Alarms:

In work areas : BLUE FLASHING LIGHT. Ala rm signals will continue as long as the H 2 S concentration is greater than 10 but less than 20 ppm or until deactivated by the H 2 S Safety Technician or the Shell Drilling

Foreman. Announcement will be made on ship’s PA system advising all personnel of the situation.

3. Characterized By:

Drilling operations area under control. Poisonous gases may be present in concentrations at threshold levels and may or may be detectable by

odor. This condition will be in effect continuously from the time the H 2 S concentration reaches 10 ppm unless it is necessary to go to Condition II or III. NOTE: It is unlikely that a continuous concentration of H 2 S during exploration drilling oper ations will be tolerat ed for an extended time periods. Shell will take remedial efforts to stop the influx of H 2 S, up to andHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 26 including well abandonment, if Conditi on I persists. Action to be taken
under Condition I is contained under Section VII “H 2 S Emergency

Procedures”

.

4. General Action:

a. Be Alert for a condition change.
b. Check safety equipment for proper functioning. Keep available for

immediate use.

c. Monitor H 2 S concentrations for general increases during drilling operations.

d. Follow the instructi ons of the supervisor.

C. Condition II: Moderate Danger to Life (H 2 S Present ≥ 20 ppm but < 50 ppm)

1. War n in g Sign:

“DANGER – POISONOUS GAS - HYDROGEN SULFIDE – DO NOT

APPROACH IF RED FLAG IS FLYING OR IF RED LIGHTS ARE FLASHING” signs will be in place on a ll sides of the drillship (Yellow with black lettering to be illuminated at night and under conditions of poor visibility.) Two foot by three f oot red flags will also be displayed.

2. Alarm:

Continuous sounding of the H 2 S siren (yelping tone) and RED LIGHT flashing. All alarm signals will continue as long as the H 2 S concentration is present at 20 ppm or more or until deactivated by the H 2 S Safety Technician or the Shell Drilling Forem an. The Vessel Master will manually trip the ship’s gas alarm. Announcement will be made on ship’s PA system advising all personnel of the situation.

3. Characterized By:

Critical well operat ions are underway or well control problems. Toxic gases are present above th reshold levels. This condi tion shall be in effect

when the H 2 S concentration is present at 20 ppm but less than 50 ppm.

4. General Action:

At a concentration of 20 ppm (15 mi nute time-weighted average) the BOE and USCG will be notified. The Vessel Management Team (VMT) will standby in the Operations Center to assist in developing H 2 S control procedures. Personnel assigned to control the H 2 S source will don

SCBAs or facemasks with a hoseline connection. All others will don SCBA then report to the Safe Brie fing Area with immersion suit and personal flotation device.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 27 D. Condition III: Extreme Danger to Life (H 2 S Present ≥ 50ppm)

1. Warning Sign:

“DANGER – POISONOUS GAS – HYDROGEN SULFIDE – DO NOT APPROACH IF RED LIGHTS ARE FLASHING” signs will be in place on all sides of drillship (Yellow with black lettering to be illuminated at night and under conditions of poor visibility).

2. Alarm:

Continuous sound ing of the H 2 S alarm (Yelping Tone) with BLUE AND RED LIGHTS flashing. Al l alarm signals will cont inue as long as the H 2 S concentration is present at greater than 50 ppm, or until deactivated by the

H 2 S safety technician or the Shell Drilling Foreman. The Vessel Master will manually trigger the ship’s gas alarm. Announcement will be made on ship’s PA system advising all personnel of the situation.

3. Characterized By:

Loss of well control or released H 2 S concentration is greater than 50 ppm.

4. General Action:

a. The evacuation vessel will be contacted for assistance with

evacuation.
b. The BOE and USCG will be notified.

c. The Shell SIMOPS Coordinator will be notifi ed (907-382-4130) d. The Incident Command Team (ICT ) in Shell’s Anchorage Office will be

notified. e. All non-essential personnel (or all personnel if the situation warrants)

shall be evacuated. Radio and other available communications shall

be used to alert all air and water craft in the immediate vicinity of the rig. The Shell Drillin g Foreman will advise the Anchorage Incident Command Team of plans to evacuate the rig. f. Evacuation will be conducted by moving personnel from Discoverer to the standby evacuation vessel. g. All people not specific ally assigned to correct or control the situation shall stay in the Designated Muster Area or Safe Briefing Area as instructed, until evacuated by a resc ue vessel or escape capsule. A suggested list of essential personnel to be left aboard is listed in Section IX. The number of essential personnel may be increased at the request of the Vessel Master, Noble Drilling Su perintendent or Shell Drilling Foreman, as necessary.

h. If the alarm sounds and it has not been preceded by Condition II, the

actions of Conditions II shall be taken. Circulation will be stopped and self-contained breathing apparatus and air line work units shall be donned by all working personnel. Th e Drilling Contractor SafetyHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 28 Representative shall check all pers onnel by roster. Vessels will be notified. The rig and shore dispat chers will also be notified of the condition and will continuously monitor the radio. i. If the flare is ignited, the burni ng or hydrogen sulfide will be converted to sulfur dioxide which is also poisonous. DO NOT ASSUME THAT

THE AREA IS SAFE AFTER THE GAS IS IGNITED. CONTINUE TO

OBSERVE EMERGENCY PROCEDURES. Follow the instructions of Supervisors.

IX. H 2 S EMERGENCY PROCEDURES

A. Condition I

If at any time 10 ppm or more (up to 20 ppm) of H 2 S is detected, the following steps will be taken:

1. The person detecting the H 2 S must IMMEDIATELY notify the driller. The driller will, in turn, notify the Toolpus her and/or the Drilli ng Superintendent who will then notify the Shell Drill ing Foreman and SIMOPS Coordinator.

2. Central Control Room notifies ship of Condition I via the ships PA system.

3. Orient the drillship relative to wind direction to minimize H 2 S exposure.

4. The H 2 S technician will establish communi cation with the control room, notifying the PIC of his intent to confirm H 2 S presence in the area of the

alarm.

5. The H 2 S Technician and designated buddy shall put on their selfcontained breathing apparat us and take hand held detectors to the sensor area registering H 2 S, and verify the presence and source of the H 2 S. The buddy system will be used.

6. The driller will shut down the mud pump, pick up to space out position and continue to rotate the drill pipe.

7. The following personnel will immedi ately put on their breathing air units.

a. All personnel on the rig floor. b. All personnel at the mud pits and shale shaker area. c. All personnel in the moon pool area. d. All personnel not in areas listed a bove will receive instruction via the PA, as to necessary response to the alarm.

NOTE: At the discretion of the Vessel Master, Drilling Superintendent, and/or Sh ell Drilling Foreman, the H 2 S Safety Technician may give the OK to doff the SCBA should theHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 29 conditions warrant. SCBAs will be worn “at the ready” until an “all clear” is given.

8. The Vessel Master, Noble Drilli ng Superintendent, or designee will alert all personnel in work areas that a Condition I exists. He shall be prepared to shut off the forc ed air circulation system and close all hatches downwind of, and below, the source of H 2 S.

9. The Mud Engineer wi ll run a Sulfide Determi nation on the flowline mud using a Garrett Gas Train pr ovided by the mud supplier or catch a closed mud sample and pu ll a Sensidyne or similar ampoule to confirm the presence of H 2 S. The Mud Engineer will don proper PPE, to include SCBA, while retrieving a sample of flow line mud to perform the test.

10. The Shell Drilling Foreman and Toolpusher will prepare plans to suppress the H 2 S as quickly as possible. Drilling operations must not proceed until t he source of the H 2 S is determined and the well is circulated. Rig floor mud pi t and shale shaker personnel will keep breathing air equipment on while monitoring this circulation.

11. The Vessel Master, Noble Drilli ng Superintendent or designee will make sure all non-essential pers onnel are out of the potential danger area (mud pit area, mud storage room, stor e room, etc.). All personnel who remain in the pot ential danger area must use the “Buddy System”.

12. The Shell Drilling Foreman shall notify the Shell Drilling Superintendent of current conditi ons and action taken who will then notify the Shell SI MOPS Coordinator.

13. The H 2 S Safety Technician will see t hat all monitoring devices are functioning properly a nd reading accurately and will increase gas monitoring activities with portable units.

14. The Shell Drilling Foreman or Noble Drill ing Superintendent, shall direct the drillship dispatcher, or the local Call and Communication Center onshore to notify all boats in the area to go upwind, to stay

on power and to maintain a continuous radio and visual watch.

15. The Shell Drilling Fo reman or Noble Dril ling Superintendent shall direct the drillship dispatcher and the Shell SIMOPS Coordinator ,the local Aviation Logistics Base onshore to notify aircraft enroute to the drillship of current conditi ons and the action to be taken.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 30 16. “DANGER – POISONOUS GA S - HYDROGEN SULFIDE – DO

NOT APPROACH IF RED LIGHTS ARE FLASHING” warning signs must be posted on all sides of the drilling rig.

17. The Shell Drilling Foreman, Ve ssel Master or Noble Drilling Superintendent will alert the dispatcher to assure continuous radio and phone watch.

B. Condition II and III

If the H 2 S Concentration reaches 20 ppm, and the well is NOT attempting to flow, the following steps will be ta ken in addition to those steps listed
above for Condition I.

1. The person detecting the H 2 S must IMMEDIATELY notify the driller. He must then notify Vessel master , Noble Drilling Superintendent and the Shell Drilling Foreman w ho will then notify the Shell

SIMOPS Coordinator.

2. Automatic audible and visual al arms in the listed areas of the drillship.

3. The Central Control Room acti vates ship-wide gas alarm system and announces change of condition.

4. The ship’s crew will orient dril lship relative to wind direction to

minimize H 2 S exposure.

5. The driller will shut down t he mud pump, pick up to space out position and continue to rotate the drill pipe.

6. All personnel will receive instruction via the PA, as to necessary response to the alarm.

7. Once breathing air equipment has been donned, the driller should:

a. Stop pipe rotation b. Space out for well control c. Be ready to close the BOP’s

d. Follow the “Well Control Procedure” in Section A-1 of the Appendix if well control problems develop.

8. The Vessel Master, Shell Dr illing Foreman, Noble Drilling Superintendent, or designee will al ert all personnel in work areas
that a Condition II or III exists. He shall be prepared to shut off the forced air circulation system and to close all hatches downwind of, and below, the source of H 2 S.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 31 9. All personnel outside of the living quarters and not listed above, must get their Type I Life Jacket and assigned SCBA, and report to the designated muster area for fu rther instructions. If both the assigned SCBA and the safe br iefing area are upwind of the wellbore, the SCBA may be carried to the designated muster area; however, if there is any doubt, the SCBA should be donned and activated immediately. If it becomes necessary to go through/across the moon pool area, rig floor or mud circulating area to get to the designated muster area, the near est breathing air equipment available is to be donned. Under a Condition II situation, those personnel inside t he living quarters will secure their SCBA and Type I life jackets and proceed to the designated muster area. Under a Condition III, all pe rsonnel inside the living quarters will go to the designated muster area with air equipment on and then proceed to the appropriate safe briefing area, as directed by the Person In Charge (PIC). Once at the safe briefing area, personnel should plug-in, close SCBA cylinder valves

, and use the Cascade System. An effort shoul d be made to conserve air still stored in the SCBA cylinder.

10. Persons should always put on breathing air equipment before assisting someone affected by H 2 S gas, and use the “buddy system”. If the affected person is stricken in a high concentration area, a safety belt with 50’ of tail line should be worn by the rescuer who should obtain standby assistance before entering the area. The “buddy system” must always be used when entering possibly

contaminated areas.

11. The Shell Drilling Foreman, Ve ssel Master or Noble Drilling Superintendent shall direct the drillship dispatcher, and the Shell

SIMOPS Coordinator to notify all boats in the area to go upwind to stay on power and to maintain a continuous radio and visual

watch.

12. The Shell Drilling Foreman, Ve ssel Master or Noble Drilling Superintendent shall direct the rig dispatcher, and the Shell SIMOPS Coordinator to notify airc raft enroute to the drillship of

current conditions and the action to be taken.

13. The “DANGER – POISONOUS GAS - HYDROGEN SULFIDE – DO

NOT APPROACH IF RED LIGHTS ARE FLASHING” signs on all sides of the drillship are to be displayed.

14. The Shell Drilling Foreman, Ve ssel Master or Noble Drilling Superintendent will aler t the radio operator to establish a 24-hourHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 32 radio and phone watch. The radio operator shall alert vessels and
the Shell SIMOPS Coordinator to standby for possible evacuation.

15. Evacuate non-essential personnel when H 2 S reaches a concentration exceeding 50 ppm in t he air. A personnel basket will

be used to evacuate to the evacuat ion vessel(s). All personnel will stay in their SCBAs until the vess el is moved upwind away from the drillship and the all clear is sounded. Personnel will “plug-in” to the Breathing Air Cascade system on t he evacuation vessel, closing the SCBA valves and using the s upplied air via the Breathing Air Cascade system to conserve stor ed air in the SCBA. Life boats (capsules) will be used if the ev acuation vessel is not readily available or if conditions require.

13. The Shell Drilling Foreman wi ll assess the situation and assign duties to each person needed to bring the situation under control. When the severity of the situatio n has been determined, all persons
will be advised. The Shell Dr illing Foreman or his designated representative will:

a. Continue to direct correctiv e action to bring the situation

under control b. Notify the Shell Drilling Su perintendent of t he situation and

results

14. The Shell Drilling Superintendent will be responsible for notifying the following regulatory agencies:

a. BOEMRE (Anchorage District)

b. U.S. Coast Guard c. Alaska Department of Natural Resources d. All other required agency
e. Shell SIMOPS Coordinator

15. If an H 2 S concentration exceeding 50 pp m in the air is recorded at the outer perimeter of the drillship, all known air and water craft in the immediate vicinity of the drills hip location will be notified by marine radio and directed to move upwind immediately

.

C. Evacuation Procedures

1. An order to evacuate the vesse l will be given by the Vessel Master

. 2. Evacuation will be conducted via personnel basket transfer from the

Discoverer to the evacuation vessel (to be determined). 3. Personnel will open th eir SCBA cylinder valve and disconnect from

the Discoverer’s cascade manifolds immediately prior to boarding the personnel basket for transfer.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 33 4. Upon transfer to the evacuation ve ssel each person will be directed

to the H 2 S muster area and connect thei r SCBA to the breathing air manifolds, then close their SCBA cylinder.

X. SPECIAL OPERATIONS

A. Other Operations

1. Logging Operations: Drilling fluid should be treated with H 2 S scavanger prior to logging to minimize the corrosive/embrittling effects of H 2 S on the wireline and logging tools. 2. Stripping Operations: Personnel must monitor displaced drilling fluid returns and wear protective breathi ng equipment in the working area when the atmospheric concentration of H 2 S reaches 20 ppm or if the well is under pressure. 3. Gas-cut drilling fluid or a well kick from H 2 S-bearing zone: When, and if, a decision is made to circulate out a kick, personnel in the working area during bottoms-up and extend ed-kill operations must wear protective breathing equipment

B. Monitor Observation During Specific Operations

During drilling oper ations the H 2 S levels indicated by the monitors must be continuously observed during the fo llowing operations after penetrating a

zone where H 2 S was identified during drilling:

1. When pulling a wet string of drillpipe 2. When circulating bottoms-up after a drilling break 3. During cementing operations (including abandonment) 4. During logging operations 5. When circulating to condition drilling fluid

XI. WELL CONTROL

The following well control practices should be initiated:

A. Trip Gas

If high trip gas or high connection gas concentrations are encountered, the degasser should be used and the gas separated and burned if that is the

best course of action.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 34 B. All Kicks

Assume any influx of formation fl uid into the wellbore contains H 2 S. When

the decision is made to circ ulate out the influx, all personnel involved will don breathing air equipment from the time the influx reaches the BOP until

it is determined whether H 2 S is present. The follo wing steps should be

taken when the influx occurs:

1. Shut in the well using normal techni ques. Record drill pipe pressure, casing pressure, and volume of influx. 2. Notify The Shell Drilling Foreman, the Noble Drilli ng Superintendent

and the Shell SIMOPS Coordinator.

3. If directed to circulate out the infl ux, proceed as outlined in the “Well

Control Procedure” in Section A-1 of the Appendix.

If the mud has been contaminated with H 2 S, it may be necessary to treat it with zinc basic carbonate (or equivalent) to treat out the H 2 S. A “Mud Treating” procedure is given in Section A-3 of the Appendix.

XII. LOST CIRCULATION

If the lost circulation occurs, proceed as outlined in the “Lost Circulation

Procedure” in Section A-2 of the Appendix.

XIII. PARTIAL EVACUATION PROCEDURE

In the event that it becomes necessary to evacuate the rig due to well control problems or fire, the Drillship Fire and B oat Station and Abandonment Procedure

will be used.

For H 2 S evacuations, see Sectio n B-6 of the Appendix.

XIV. RESPONSIBILI TIES AND DUTIES – H 2 S

A. All Personnel

1. It is the responsibility of all pers onnel on the drillship, as well as any other personnel assisting in the drilling or abando nment of the well, to

familiarize themselves with t he procedures outlined in the “H 2 S Contingency Plan”.

2. Each individual is responsible for seeing that his assigned safety equipment is properly stored, easily accessible and routinely

maintained.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 35 3. Each person must familiarize hi mself with the location of safety equipment aboard the drillship and be abl e to use all safety equipment

at a moment’s notice. The location of all safety equipment is given in

Section C-1 of the Appendix.

4. All personnel must read the Contingency Plan and sign the

“ Contingency Plan Memor andum of Understanding ”.

5. Report any indications of H 2 S to those in the area first, then to VESSEL MASTER, Drilling Superintendent and/or to The Shell Drilling

Foreman.

B. Shell Drilling Foreman

1. The Shell Drilling Foreman is responsible for thoroughly understanding and enforcing all aspects of the “H 2 S Contingency Plan”.

2. The Shell Drilling Foreman is responsible fo r seeing that all safety and emergency procedures outlined in the “H 2 S Contingency Plan” are observed by all personnel participating in the drilling of the well.

3. The Shell Drilling Foreman will ad vise The Shell Drilling Superintendent and the Shell SIMOPS Coordinator whenever the procedures, as specified herein, cannot be complied with.

4. The Shell Drilling Foreman is responsible for equipment installation on the drillship prior to s pudding a potential sour gas well as described

under Section V “Safety Equipment”.

5. The Shell Drilling Foreman in conjuncti on with the Noble Drilling Superintendent is responsible for sch eduling training for all Shell, contractor and Noble personnel assigned to the drillship.

6. If the presence of H 2 S is reported and confirmed, The Shell Drilling Foreman is responsible for imm ediately advising the Emergency Room, the Vessel Master, the SIMO PS Supervisor, and the Drilling Superintendent.

7. The Shell Drilling Foreman shall restrict the number of personnel on the drillship to a minimum duri ng expected hazardous operations.

C. Vessel Master / Noble Drilling Superintendent

1. The Vessel Master and/or Dril ling Superintendent are responsible for thoroughly understanding the contents of the “H 2 S Contingency Plan”. In the absence or incapacit ation of the Vessel Master, orHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 36 Noble Drilling Superintendent. The Toolpusher will assume responsibilities designated herein.

2. It is the responsibility of the Vessel Master and/or Drilling Superintendent to see that all safety and emergency procedures

outlined in the “H 2 S Contingency Plan” are observed by all Noble drilling and marine personnel aboard the rig.

3. The Drilling Superintendent shares the responsibility with the Shell Drilling Foreman in scheduling trai ning for personnel assigned to the drillship.

4. The Vessel Master and/or N oble Drilling Supe rintendent will be responsible for directing the shu tting off the forced air circulating system and closing all hatches in the event that H 2 S is detected in the atmosphere at any time.

5. The Vessel Master and/or N oble Drilling Supe rintendent will be responsible for inspecting the drillship to make sure that all passageways remain unobstructed.

6. The Vessel master and/or N oble Drilling Superintendent is responsible for alerting all personnel during a Condition I, II, or III alert and for displaying warning signs and flags (if used) as outlined

under Section VII “Operating Conditions – Classification”.

7. The Vessel Master is responsible for choosing the drillship heading to provide the highest level of protection for all personnel in the

event H 2 S is detected.

D. H 2 S Safety Technicians

1. There will be at least two (2) H 2 S Safety Technicians aboard the vessel at all times during co mpliance operations. One H 2 S Safety Technician will work the day shift and the other will work the night shift. Both will respond to drills or H 2 S release at any time.

2. Is responsible for performing a week ly inventory to assure that all safety equipment is being properly stored and maintained.

3. Is responsible for logging the arrival and departure of all personnel on the drillship, as per BOE requirement.

4. Is responsible for the H 2 S training, which includes the use, maintenance, and storage of the safety equipment.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 37 5. Is responsible for issuing H 2 S safety equipment to arriving personnel on the rig and for colle ction of same for departing personnel.

6. Is responsible for the maintenance and repairs of all H 2 S safety equipment.

7. Is responsible for the required inspection and sanitizing of the H 2 S safety equipment.

8. Is responsible for the maintenance of H 2 S Safety Training Class Attendance Records, and other record keeping required. He shall
furnish the Shell Drilling Foreman a copy of all class attendance

records.

9. Will observe and assist during weekly H 2 S drills.

10. Will test the H 2 S sensors daily for response. A copy of the results will be given to The Shell Drilling Foreman.

11. Will calibrate the H 2 S sensors weekly. A copy of the results will be given to The Shell Drilling Foreman.

E. Dispatcher/ Radio Operator

1. The Dispatcher is responsible fo r notifying all personnel in the area of the rig (including any workboats and/or helicopters) of a change

in conditions. The Shel l SIMOPS Coordinator s hall also be notified.

F. Noble Toolpusher/ Driller

1. The Toolpusher and Driller must be completely familiar with the steps each must take during a Cond ition I, II, or III Emergency as
outlined under Section VIII “H 2 S Emergency Procedure”.

2. The Toolpusher and Driller must be completely familiar with their assigned duties during well control and lost circulation problems as

outlined under Section XI “Well Control” and Section XII “Lost

Circulation”.

3. In the absence or in capacitation of all She ll Drilling Foremen, the

Vessel Master and Noble Drill ing Superintend ent then the Toolpusher will assume the lead role in H 2 S response as designated herein.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 38 G. Mudlogger

1. Is responsible for the switch insi de the mudlogging unit that controls the forced air duct leading to the unit.

2. Is responsible for a multi-gas detector which will be kept in the mudlogging unit.

H. Mud Engineer

1. Must have a Garret Gas Train Kit for measuring the sulfides in the mud if a water-based drilling fluid is used, and must be fully trained

on its use

.

2. Must be familiar with the “Mud Treating” procedure for H 2 S cut mud

in Section A-3 of the Appendix.

3. Is responsible for assuring that the rig has a sufficient supply of 100% zinc carbonate or an equivalent H 2 S scavenger.

I. H 2 S Flaring

1. When flaring, hour ly readings for SO 2 and H 2 S will be monitored with a fixed or portable instrum ent implementing the buddy system.

2. Detection of 5 ppm of SO 2 : Personal protective measures will be taken by personnel in work ar eas affected. Self contained breathing apparatus will be utilized to take hourly readings using the buddy system. All unnecessary personnel will be evacuated from the affected area and if necessary from the facility using only designated personnel to take corrective action. The designated personnel will be the same as listed for an H 2 S emergency response. Briefing areas will be utilized as necessary. H 2 S readings will be monitor ed and logged along with SO 2 readings.

3. Detection of 2 ppm of SO 2 : Personal protective measures will be taken by personnel in work ar eas. Self contained breathing apparatus will be utilized to take hourly readings using the buddy system. All unnecessary personnel will remain out of the affected area upwind. Quarters or briefing areas will be utilized as needed pertaining to emergency conditions as described in this plan for H 2 S

and the concentration of SO 2.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 39 XV. PROCEDURE FOR INFO RMING PERSONNEL OF H 2 S CONTINGENCY PLAN

A. Aboard Drillship

1. There will be a complete copy of this H 2 S Contingency Plan

available in the Shell Drilling Foreman’s office, Vessel Master’s office, Emergency Room

, Radio Room and the Noble Drilling Superintendent’s office.

2. ALL Personnel arriving at the rig will report immediately to the H 2 S Safety Technician for familiarization with the Contingency Plan. Each person will be required to si gn a log indicating that they have been briefed on, and do understand, this H 2 S Contingency Plan.

3. The H 2 S Safety Technician will train the crews and familiarize them

with the “ Contingency Plan Memor andum of Understanding ”.

Written records will be maintained.

B. Aboard Support Vessels

A copy of this H 2 S Contingency Plan will be given to the Master of each of the support vessels. They will be required to sign a l og indicating that they have read and understand the plan.

XVI. SEARCH & RESCUE TEAMS

A. Primary Goal

Rescue team members must realize t hat the primary goal of the team should be to inspect all ar eas of the drillship fo r personnel who have been overcome by H 2 S or SO 2 . However, from a pr actical stand point, the potential for someone to be overcome is greatest during a Condition III release as indicated by the Flashing BLUE & RED lights and siren, it is essential that the Rescue Teams report to the staging area & report in with their assigned SCBA units and then imm ediately begin a search of the

below deck areas.

B. Critical Areas

During drilling or P&A activities, the four most critical areas can be defined as the shale shaker area, mud pit area, possum belly and drill floor area. The trip tank area is also critical when tripping pipe. Accordingly, the H 2 S Emergency Station Bill is designed to ensure that such areas are quickly
evaluated after and/or dur ing any significant H 2 S release. For example,

the H 2 S Technicians during such times ensure that the shaker area and trip tank will be checked, while the Toolpusher and Noble DrillingHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 40 Superintendent ensure the drill floor is checked. In addition, the Rescue

Team ensures that all below deck water-tight doors will be secured to prevent migration of gas.

C. Unconscious Victims

Rescue Team members must realize that in the event an unconscious victim is found, it may or may not be necessary to move the victim before administering the necessary first-aid. The determining factor will be the presence of H 2 S or some other threat whic h poses an immediate danger to victim as well as the rescue per sonnel. Since procedures call for the mud pumps to be shut down if H 2 S is detected, it is unlikely that large

volumes of H 2 S will continue to be released.

D. Purging the Area

This coupled with the ventilation systems presently on the drillship, enhance the possibility that any H 2 S or other gas will be quickly purged from an area, such as t he pit area. Persons found unconscious may have tripped or fallen when responding to the H 2 S alarms, and as a result may have suffered neck or spinal injuries. In such a case, moving the victim could prove fatal. Therefore, it is essential that the Rescue Team properly determine not only the victim condition , but also the condition of the surrounding area.

E. Procedures and Drills

1. CONDITION I

a. ON-DUTY TEAMS: IN THE EVE NT OF CONDITION I OR II

1) Proceed to staging area and report in, then don 30 minute SCBA. Do not open cylinder valve or don facepiece.
2) Check portable H 2 S detectors and Clear-Com Devices

2. CONDITION II or III

a. ON-DUTY TEAMS: IN EVENT OF AN H 2 S RELEASE

1) Proceed to staging area and report in, then don assigned
RESCUE TEAM SCBA.
a. Check portable H 2 S detectors and Clear-Com devices.

b. In the event a team membe r(s) is missing, proceed as a group of 3 or 2. Do not proceed alone.

2) Proceed in teams down to designated start point.
a. Secure watertight doors and hatches along way to prevent migration of H 2 S.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 41 3) Team 1 – Follow normal resc ue team procedures as outlined
in the Station Bill.

Team 2 – Follow normal rescue team procedures as outlined
in the Station Bill.

a. Continue to secure all wa tertight doors and hatches to prevent gas migration.

4) In the event you encounter a person(s) in distress:

a. One team member checks to see if victim is breathing

while other team member checks for H 2 S in area.

 If victim is breathing and no contamination is present, alert the Medical staff in the infirmary.

Continue to monitor area with H
2 S Detectors.

 If victim is breathing and/or contamination is present, remove victim to safe area immediately and then notify the Medical staff.
b. Verify area is safe from H 2 S with portable detector, before removing mask.
c. Check victim again for breathing and pulse (heartbeat).

d. Administer mouth-to-mouth re suscitation if victim is not breathing or CPR if vi ctim has no heart beat.

e. Alert the Medical staff immedi ately. Do not leave anyone

in distress unattended.
f. Obtain oxygen resuscitator and stretcher. Typically, this equipment will be brought to scene by Medical staff..

 Replace mouth-to-mout h activities with the

mechanical resuscitator.

 Transfer patient(s) to Safe Briefing Area or Infirmary as quickly as possible for further

treatment.

NOTE: When transferring a patient, every effort must be made to

use a route that has been veri fied to be gas free. If a breathing patient must be tran sferred through an area that could potentially be co ntaminated, it will be necessary to supply a safe source of breathing air to the patient.

5) Rescue Teams should meet in the Staging Area or designated Safe Briefing Ar ea after completing their respective search activities.
a. If only one team has conduc ted the search, then proceed from the staging to the Desi gnated Safe Briefing Area.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 42 b. Report to supervisory per sonnel and be prepared to conduct additional search, rescue and/or hazard

assessment activities as needed.
c. Check SCBA cylinder to ensur e it contains a minimum of 1500 psi; recharge or replace the cylinder if necessary.

a. OFF-DUTY RESCUE TEAM: IN THE EVENT OF AN H 2 S

RELEASE 1) Be prepared to assist as needed.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 43 

## APPENDIXHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 44 

### APPENDIX – SECTION A

PROCEDURES

SECTION A-1



### WELL CONTROL PROCEDURES

All efforts should be made to prevent a well ki ck, which may result from gas cut mud, abnormal pressure, and loss in circulation, or swabbing. Should any of the following conditions occur, the well should be checked for flow.

1. Increase in flow across the shale shaker.
2. Gain in pit volume.

3. Hole does not take correct fill on trips.
4. Significant drilling break.

5. Decrease in pump pressure.
6. Significant increase in connection gas.

If well flow is confirmed, t he following actions will be taken:

Shut-In Procedure While Drilling

1. Sound kick alarm

2. Pick up to space out position and break off top drive or false kelly
3. Install stab-in safety valve (TIW Valve) in top of drill string and close

4. Close BOP and make certain well is shut-in
5. Re-install top drive or false kelly and open TIW valve

6. Read and record:
a. Shut-in drillpipe pressure, if any
b. Shut-in casing pressure

c. Mud volume gained.

Shut-in Procedure While Tri pping or Running Casing

1. Sound kick alarm

2. Pick up to space out position

3. Install crossover and TIW valve in top of drill string or casing and close

4. Close BOP and check to see that well is shut-in
5. Make up top drive or false kelly ont o drill string or casing and open TIW valve

6. Read and Record:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 45 a. Shut-in drillpipe or casing pressure, if any
b. Shut-in annulus pressure

c. Mud volume gained.

Shut-in Procedure With Pipe out of the Hole

1. Close well in with blind/shear rams and check to see that it is shut-in 2. Close hydraulic choke and open choke line

3. Read and record: a. Shut-in well pressure b. Mud volume gained

The handling of the H 2 S kick will normally involve one of the two following techniques:

 Pumping the kick away

 Circulating the kick out

The technique selected must be based on the conditions existing at the time of the occurrence. The selected technique will have as its objective the protection of human life, protection of the environment, and protection of property respectively.

As long as it is operationally feasible and safe to do so, all kicks (especially H 2 S kicks) will preferentially be bullheaded away rather than circulat ed out. This plan of action has the advantage of minimizing the surface risk to personnel, environment, and service equipment.

In some cases, it will be necessary to set a barite or cement plug over the H 2 S-bearing formation to accomplish proper well control. If drilling cannot safely proceed the well may be permanently abandoned.

If the decision is made to circulate out the H 2 S kick, operations s hould not be initiated until briefings have been held with all personnel in volved, equipment is made ready and alert/warning signs are displayed.

Regardless of which technique is employed to deal with an H 2 S kick, all personnel on the rig floor and mud circulati ng areas should secure SCBA s and ensure that they are “at ready” should donning become necessary.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 46 SECTION A-2



### LOST CIRCULATION PROCEDURE

If lost circulation is experienc ed during any phase of the drilling operat ions, every effort will be made to fill the hole and keep it full. The driller should:

1. Pick up to space out positi on and shut down the mud pumps
2. Notify the Toolpusher and Shell Dr illing Foreman as soon as practical
3. Fill trip tank with fluid (seawater, dr illing water or drilling fluid may be used). Consideration should be giv en to keeping one side of t he trip tank filled with a lower weight fluid duri ng drilling operations
4. Begin filling hole from the trip tank. If hole will not fill from the trip tank, begin pumping fluid into the annulus keeping tr ack of all fluid volumes pumped

NOTE : Pumping excessive volumes of light weight fluid has the risk of reducing hydrostatic pressure in the wellbore and inducing the well to flow.

5. Work the drill string while attempting to fill and regain circulation to avoid differential sticking

6. When hole fills, determine and record t he volume of water required to fill the

hole.

a. Check well for flow. If well is static and hole stands full, monitor for possible flow. Keep trip tank on the hole.
b. If well is flowing, shut well in per “Well Control Procedure”
7. Procedure(s) to regain ci rculation will be developed ba sed on hole conditions.
DO NOT PULL INTO CASING until approved by the Sh ell Drilling Foreman.
One or more of the follo wing methods will be used:

a. Introducing lost circulation ma terials into the mud system and/or minimizing mud weight
b. Spotting lost circulation pills over the suspected thief zone

c. Bullheading cement or other sealing fluid into the thief zone

d. Pulling up into the casing to allow the hole to heal
e. If the loss circulation problem is se vere, consideration will be given to setting an additional casing string thr ough the thief zone and cementing it in placeHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 47 SECTION A-3



### MUD TREATING

1. Zinc oxide, or an equivalent H 2 S scavenger, will be used to treat out H
2 S in the

mud system. It should not be added to the system until solu ble sulfides are detected in the mud by t he Mud Engineer and approval is given by the Shell Drilling Foreman

2. After H 2 S is detected, the init ial treatment of the H 2 S scavenger should be sufficient to treat the soluble sulfides only to a zero concentration. Treatment in

excess is to be avoided.

3. The mud system must be maintained with a pH greater than 10.0. The pH of the mud system will be maintained by adding lime or caustic soda or equivalent and the high pH should be maintained belo w compliance depth. A rapid decrease in pH is a possible indicati on of the presence of H 2 S in the mud system.

4. The mud system could contain H 2 S and/or sulfides if agi tation is not adequate to

remove all of it.

5. The Mud Engineer will have a Garrett-Gas-Train test kit aboard the vessel readily

available to conduct a test for soluble su lfides that will confirm the presence and approximate amount of H 2 S in the mud.

6. From compliance depth to total depth, the Mud Engineer will test for sulfides at least every 12 hours using Garrett-Gas-Trai n test kit. Detailed instruction for performing these tests will be mainta ined on the rig (API RP 13B).

7. The results of these checks or any other indication of H 2 S in the mud system will be included as a routine part of the mud engineer’s daily reports.

8. Pilot tests on mud samp les will be performed to det ermine, in advance, the
effects of 1⁄2 and 1 lb/bbl concentrations of the H 2 S scavenger on the rheological properties of the mud system.

Mud Treatment Plan Specific to an H 2 S Occurrence

Pre-Planning 1. At least one complete Ga rrett Gas Train and required supplies must be available on the drillship before dril ling commences on any Chukch i Sea exploration well.

Because of the distance from sources of supply and logistical considerations, two complete Garrett Gas Trains should be available on the rig.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 48 2. A baseline sulfide level in the circ ulating system will be established well in advance to entering potential H 2 S zone. 3. Adequate scavengers (zinc oxide or equi valent) will be on board prior to entering potential H 2 S zone. Enough zinc oxide or ot her scavenger will be on board to add twice the amount necessary to remove all H 2 S to the entire circulating system (e.g., two complete treatment s of zinc carbonate at 2 ppb). 4. The PSM (POM) in the circulating system should be ≥ 5 mL prior to entering potential H 2 S zone. 5. The electrical stability will be increased to as high as practical prior to entering potential H 2 S zone (>500 mV ES is sufficient).

Treatments and Procedures
1. Maintain PSM in the suction ≥ 5 mL.
2. If the PSM at the flow line is depleted to <3 mL, the suction PSM should be

increased to commensurate with the depletion rate.

3. Zinc oxide should not be added to the system unless soluble sulfides (greater

than the established base line) are detected in t he mud system by the Mud Engineer and approval is given by the Shell Drilling Foreman.

4. If an H 2 S increase is seen to 200 mg/L above the baseline through the Garret Gas Train, 1⁄4 ppb zinc oxide s hould be added to the mud system. 5. If an increase of 200 mg/l to 400 mg/l abov e the baseline is observed, 1⁄2 ppb zinc oxide should be added to the system. 6. If an increase of 400 mg/l to 600 mg/l is noticed, 3⁄4 ppb zinc oxide should be

added. 7. If an increase of 600 mg/l to 800 mg/l is noticed 1 ppb zinc oxide should be

added.

8. These treatments are based on the assumption that 1 ppb zinc oxide will treat out 800 mg/l to 1,200 mg/l H 2 S in the drilling fluid. . 9. The objective will be to maintain the su lfide level at the bas eline. Anything above the baseline will have the potential for em brittlement and/or co rrosion of the drill string and other critical ri g components to occur.
10. The Garret Gas Train test will be run a mi nimum of once every 12 hrs. (or as hole conditions dictate). It is very important to adjust the baseline to set a target for follow-up treatment it in the event that H 2 S is encountered as drilling progresses. 11. Pilot testing with zinc oxide should be done to ensure that effective treatments are being made to the system to minimize any H 2 S picked up while drilling. 12. In the event of a temp orary abandonment or suspension 2 ppb zinc oxide will be added to the drilling fluid left in the hole.

Note: The objective is to treat all active su lfides in the mud system with zinc oxide to form ZnS (zinc sulfide) which is a very stable compound in a reaction that is essentially non-reversible. However, caution should be exercised to match

treatments to active sulfides above the bas eline so as to minimize potential toxic impacts.Hydrogen Sulfide Contingency PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc.May 201149Zinc Oxide Treatment0500100015002000250030003500 0.25 0.5 0.75 1 1.25 1.5 1.75 2 2.25 2.5 2. 7 5 3 3. 25 3. 5 3 . 75 4Zinc Oxide (ppb)

Soluble Sulfides Above Baseline (mg/l)Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 50 

### APPENDIX-SECTION B

GENERAL INFORMATION

SECTION B-1



### TOXICITY OF VARIOUS GASES

Common Name Chemical

Formula Specific Gravity 1 PEL (OSHA) 2 STEL 3 Lethal 4
Limit, ppm

Hydrogen Cyanide HCN 0.94 10 150 300

Hydrogen Sulfide H 2 S 1.18 10 15 600

Sulfur Dioxide SO 2 2.21 2 5 1000

Chlorine Cl 2 2.45 1

Carbon Monoxide CO 0.97 35 200/1 hour 1000

Carbon Dioxide CO 2 1.52 5000 5% 10%

Methane CH 4 0.55 90000 (9%) Combustible (Above 5 % in air)

1 Air=1.0

2 Permissible - Concentration at which is believed that all workers may repeatedly be exposed, day after day , without adverse effect.

3 STEL - Short Term Exposure Limit.

4 Lethal - Concentration that will caus e death with short-term exposure.



## PROPERTIES OF GASES

A. CARBON DIOXIDE

1. Carbon Dioxide is usually considered chemically iner t although it is both a suffocant and toxic to humans in high concentrations. It is 1.52 times

heavier than air and will concentrate in low areas of still air. Humans cannot breathe air containing more than 10% CO 2 without losing consciousness. Air containing 5% CO 2 will cause disorientation in a few minutes. Continued exposure to CO 2 after being affected will cause convulsions, coma, and respiratory failure.

2. The PEL-TWA 8 of CO 2 is 5000 ppm. STEL (15 min) to CO 2 is 50,000 ppm (5%).Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 51 3. This gas is colorless, odorless, and can be tolerated for short time periods in relatively high concentrations. In higher concentrations, short term exposure can result in suffocation due to displacement of oxygen from the environment. Continued exposure can result in a blood pH drop with subsequent toxic impacts.

B. HYDROGEN SULFIDE

1. Hydrogen Sulfide (H 2 S) is a colorless, transparent, flammable gas. It is heavier than air and, hence, may accumulate in low places. 2. Although the sli ghtest presence of H 2 S in the air is normally detectable by it characteristic “rotten egg” odor, it is dangerous to rely on the odor as a means of detecting excessive concent rations because the sense of smell is rapidly lost, allowing lethal conc entrations to be accumulated without warning. The following table indicates the poisonous nature of H 2 S.

CONCENTRATION in AIR

EFFECTS

% H 2 S ppm gr/100

SCF 1

0.001 10 0.65 Safe for 8 hours without respirator. Obvious and unpleasant

odor.

0.0015 15 0.975 Safe for 15 minutes of exposure without respirator.

0.01 100 6.48 Kills smell in 3-15 minutes ; may sting eyes and throat IDLH 0.02 200 12.96 Kills smell quickl y; stings eyes and throat.
0.05 500 32.96 Dizziness; br eathing ceases in a few minutes; need prompt artificial respiration. 0.07 700 45.92 Rapid Unconsciousness; death will result if not rescued promptly.
0.1 1000 64.80 Instant unconsciousness, followed by death within minutes.

1 Grains per 100 Standard Cubic Feet

Treatment Procedures for Hy drogen Sulfide Poisoning

A. Remove the victim to fresh air. B. If breathing has ceased or is labored, begin resuscitation immediately.

NOTE: This is the quickest and preferred method of cl earing victim’s lungs of contaminated air; however, under di saster conditions, it may not be practical to move the victim to fresh air. In such instances, where those rendering first aid must continue to wear masks, a resuscitator should be

used. C. Apply oxygen resuscitator to help purge H 2 S from the blood stream. D. Keep the victim at rest and prevent chilling. E. Get victim under physician’s care as soon as possible.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 52 C. SULFUR DIOXIDE

1. Sulfur Dioxide (SO 2 ) is a colorless, non-flam mable, transparent gas.
2. SO 2 is commonly produced du ring the burning of H 2 S. Although SO 2 is heavier than air, it can be picked up by a breeze and carried downwind at elevated temperatures. Since SO 2 is extremely irritating to the eyes and mucous membranes of the upper respir atory tract, it has exceptionally good warning powers in this respect. The following table indicates the

toxic nature of SO 2

.

SO 2 Effects

CONCENTRATION in AIR

EFFECTS % SO 2 PPM

0.003 –

0.005 3 to 5 Pungent odor, norma lly a person can detect SO 2 in this

range.
0.012 12 Throat irritation, coughing, constriction of the chest, tearing and smarting of eyes.

0.15 150 So irritating that it c an only be endured for a few minutes.

0.05 500 Causes a sense of suffocation, event with the first breath.

0.10 1000 Death may result unless rescued promptly.

3. If gas containing H 2 S is burned, the following steps must be taken to protect against SO 2

.

a. Monitor the SO 2 concentration in the air with portable or strategically placed fixed devices capable of det ecting a minimum of 2 ppm or SO 2 ; b. Take readings at least hourly and at any time personnel detect SO 2 odor or nasal irritation; c. Implement the personnel protective measures specified in the H 2 S Contingency Plan if the SO 2 concentration in the work area reaches 2 ppm; and d. Calibrate devices every 3 months if you use fixed or portable electronic sensing devices to detect SO 2

.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 53 SECTION B-1

H 2 S CONTINGENCY PLAN MEMO RANDUM OF UNDERSTANDING

Signature Form:

Company: _________

_____________________

Well: _____________

_____________________

I, ________________________, an employee of ________________________, have

been briefed on the H 2 S contingency plan and understand it.

________________________________________

_______________ ______________ Signature Date

NOTE: This signed form will be kept on file on the drillship.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 54 SECTION B-2

BREATHING AIR EQUIPMENT DRILLS FOR

ON-DUTY PERSONNEL

On-duty personnel include Drilling, Marine and Roustabout Crew, Vessel Master, Noble Drilling Superintendent, H 2 S Safety Technician, the Shell Drilling Foreman and all other personnel on tour including cont ractors and catering personnel..

The Mudlogger and Mud Engin eer will report to the Must er Area, and then take
directions from the PIC.

An H 2 S drill and training session will be conducted weekly.

The purpose of this drill is to instruct the cr ews in the operation an d use of breathing air

and H 2 S related emergency equipment and to allow the personnel to become acquainted with using t he equipment under working conditi ons. The crews should be trained to put on the breathing air equipment within one minute after an H 2 S emergency

has been alerted.

The following procedure should be used for w eekly drills. The Shell Drilling Foreman, VESSEL MASTER, and Dril ling Superintendent must be sati sfied that the crews are proficient with the equipment.

NOTE: The drill will be c onducted as outlined under “Emergency Procedures for

Condition II and Condition III”

1. All on-duty personnel should be in formed that a drill will be held.

2. The H 2 S Safety Technician should initiate the drill by signaling as he would if he

detected H 2 S.

3. The driller should shut down the mud pumps, pick up to space out position and continue to rotate the drillpipe while he and the drilling crew don their breathing air equipment. The Mudlogger, Mud Engineer, Toolpusher, Noble Drilling Superintendent, and affected Shell personnel should also don their breathing air equipment.

4. The driller will proceed as if the well is flowing; simulate closing the well in, but

DO NOT ACTUALLY CLOSE THE BOP without orders from the Toolpusher.

5. After reporting to the Muster stati on, The Mud Engineer will be directed to perform a flowline check for mud weight and funnel viscosity, and catch a mud sample for the sulfides test on the mud. This part of the drill is important, as

Shell wants to make it a standard practice that a sulfides test be run every timeHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 55 anything unusual happens. In a DRILL ON LY, it may not be necessary to perform the sulfides test on the mud.

6. During the Drill, the Shell Drilling Foreman, Ve ssel Master, Noble Drilling Superintendent, and the H 2 S Safety Technician will observe to make sure that everyone is using their equipment properly.

7. Resume normal operations.

8. The Vessel Master, Nobl e Drilling Superintendent, She ll Drilling Foreman, and

the H 2 S Safety Technician will hold a review to discuss results of the drill with those participating.

9. H 2 S drill performance, new H 2 S considerations at the fa cility, and other updated

H 2 S information should be discussed at a sa fety meeting at least monthly.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 56 SECTION B-3

BREATHING AIR EQUIPMENT DRI LLS AND TRAINING SESSIONS

FOR OFF-DUTY PERSONNEL

Off-duty personnel include all personnel aboard the drillship with the exception of the On-Duty Drilling, Marine and Roustabout Crew, Mudlogger , Mud Engineer, Noble Drilling Superintendent, H 2 S Safety Technician, and Shell Drilling Foreman.

An H 2 S drill and training session will be conducted w eekly for all off-duty personnel to simulate steps that must be taken by per sonnel who are on their time off when an H 2 S

alarm is activated.

This training will be conducted to instruct personnel in the operat ion and use of selfcontained breathing apparatus and H 2 S related emergency equipment, and to review various operating procedures in the “H 2 S Contingency Plan”.

Initial Drills should include:
1. General information about the self-c ontained breathing apparatus (SCBA), including air supply time limit, connection to breathing air manifold(s), and proper packing and storage. Spectacle Kits for SC BAs should be utilized in place of contact lenses or spectacles. 2. How to put the mask on and test for leaks around face and hose connections. All personnel will be informed of the re strictions against having beards.

These drills should be conducted as often as necessary to acquaint the crews with the equipment. After the Shell Drilling Fore man, Vessel Master and/or Drilling Superintendent are convinced that all pers onnel are trained, a weekly drill must be conducted. This drill may be initiated any ti me. Prior to the drill, the Drill and Marine crew on duty must be informed that it is only a practi ce drill. This drill will be initiated by the Condition II or Condition III general alarm signal given by the Vessel Master, Drilling Superintendent or the Shell Dril ling Foreman. At this time , all off-duty personnel will immediately get their assign ed SCBAs and Type I Life Jackets and report to the

“MUSTER AREA”. Personnel should be trained to report to the “MUSTER AREA”, then

to “SAFE BRIEFING AREA” with their emer gency equipment within three minutes after the alarm has sounded. A training and info rmation session will be conducted after each drill to answer any H 2 S related questions and to cover one or more of the following:

 Condition I or II alerts and st eps to be taken by all personnel.

 The importance of wind di rection when dealing with H 2 S.

 Proper use and storage of all types of breathing equipment.

 Proper use and storage of oxygen resuscitators.

 The “buddy system” and t he procedure for rescuing a person overcome by

H 2 S.

 Responsibilities and duties.

 Location of H 2 S safety equipment.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 57  Other parts of the “H 2 S Contingency Plan” that should be reviewed.

NOTE: A record of attendance must be kept for weekly drills and training session.

These drills must also be documented on t he IADC Report and the Shell Daily Drilling Report.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 58 SECTION B-4

HYDROGEN SULFIDE TRAINING CURRICULUM

At the docks and on the rig; eac h individual will be asked if they have been cleared by a physician to use a respirator. This require ment will be the responsibility of each company or individual bef ore coming aboard the rig.

Each person will be informed on the restricti ons of having beards and contact lenses. They will also be informed of the availability of spectacle kits. Personnel with beards or moustaches that extend past the corners of the mouth mu st shave and continuously restrict the regrowth of faci al hair while drilling operations are in progress. Both Noble and Shell HSSE representatives will monitor personnel to ensur e that the restriction on

facial hair is enforced. This restricti on applies to all personnel aboard the vessel including visitors.

The safety program is outlined in the H 2 S Contingency Plan. This plan will be available on the rig. Each individual will read and sign “Considerations during the Drilling or Abandonment of a sour gas well.”

After the H 2 S equipment is rigged up, all personnel will be H 2 S trained and put through a drill. Any deficiencies will be corrected.

Training Completion cards are good for one year and will indicate dat e of completion or expiration. Personnel previously trained on another facility and visiting the drillship must attend a “supplemental briefing” on H 2 S equipment and proced ures before beginning duty. Visitors without current H 2 S certification who remain on the facility more than 24

hours must receive full H 2 S training given all crew member s. A “supplemental briefing” will include but not be limited to: location, use and donning of an a ssigned respirator, familiarization with safe briefing areas, alarms with instruction on re sponsibilities in the

event of a release and hazards of H 2 S and SO 2

.

Topics for full H 2 S training shall include, but not limited to the following:

I. Brief Introduction on H 2 S

A. Slide or VCR Pres entation (If available)

B. H 2 S Material will be distributed C. Re-emphasize the properties , toxicity, and hazards of H 2 S.

D. Source of SO 2

.

II. H 2 S Detection A. Description of H 2 S sensors B. Description of warning system (how it works and its location)

C. Actual location of H 2 S sensors

D. Instruction on use of pump type detector

E. Use of card detectors , ampoules, or dosimeters F. Use of combustible gas detectorHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 59 G. Other personnel detectors used H. Alarm conditions I or II (10 ppm, 20 ppm)

III. H 2 S Protection A. Types of breathing apparatus prov ided (30 minute SCBA & Work Units with voice diaphragms for communication) B. Principle of how br eathing apparatus works.
C. Demonstration on how to use breathing apparatus. D. Location of breathing apparatus.

IV. Cascade System A. Description of Cascade system B. How System works C. Location of cascade with reference to briefing areas. D. How to use cascade system with recharge/refill of SCBA E. Importance of wind direction and actual location of windsocks F. Purpose of compressor/function

V. H 2 S Rescue and First Aid A. Importance of wind direction B. Safe briefing area C. Buddy System

D. H 2 S Symptoms

E. Methods of rescue

VI. Hands on Training A. Donning/familiarization of SCBA B. Donning/familiarization of ot her breathing apparatus/ work units

C. Familiarization of cascades

D. Use of O 2 resuscitator E. Alarm conditions – upwind briefing areas, etc. F. Duties and responsibili ties of all personnel

G. Procedures for evacuation

H. Search and Rescue teams

VII. Certification A. Testing on material covered.

NOTE: TRAINING AND DRILLS WILL INVOLVE SUPPORT VESSELS TO THE EXTENT FEASIBLE AND PRUDENT, AS DETERMINED BY THE VESSEL

MASTER AND SHELL DRILLING FOREMAN.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 60 Technical Division

STANDARD FIT TEST FORM

NAME: __________________ _________________ DATE:

______________________ ID NUMBER / SSN: ________________

_____________________ ________________ COMPANY: ______________

_____________________________________________ LOCATION: __________________________

________________________ _________ MASK TYPE: ______________________________ SIZE: _______________________

QUALIATIVE FIT TEST: QUANTATATIVE FIT TEST:

TEST NUMBER FIT FACTOR P/F

Test #1 Normal Breathing

Test #2 Deep Breathing

Test #3 Head Side to Side

Test #4 Head Up & Down

Test #5 Talking

Test #6 Bend and Touch Toes

Test #7 Normal Breathing

OVERALL FIT FACTOR OVERALL PASS / FAIL

________________________ __________ _________ _________________________ Person Conducting Test Date

________________________ __________ _________ _________________________ Person Taking Test DateHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 61 Technical Division

TRAINING ROSTER FORM

Company: Location: Lease: Chukchi Sea Date:

Drillship: Noble Discoverer Instructor:

Topics Discussed:

Equipment Discussed:

Equipment Demonstrated:

Film Shown: Job Number:

No. NAME (Print) S.S. # Company Signature Date

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 62 SECTION B-5

EMERGENCY TELEPHONE LISTING

SHELL GULF OF MEXICO INC.

A. Initial detection, but less than 10 ppm – Notify the Anchorage Office or residence of one of the following:

Shell Drilling S uperintendent TBD Shell Drilling E ngineer
Shell SIMOPS Coordinator TBD

TBD
Shell HSSE Advisor TBD

Alaska Emergency and Incident Reporting

Number: 877-273-2443

(Operated by Purcell Security) 907-264-7777

B. Moderate danger – 20 ppm – Notify Anchorag e Office or one of above at residence. Division office will notify the appropriate aut horities. The M.M.S. and Coast Guard

must be notified.

DRILLING CONTRACTOR

Noble Rig Manager TBD Noble Anchorage Office TBD

Noble Houston Office TBD

AREA HOSPITAL FACILITIES

Providence Alaska Medical

3200 Providence Dr. Anchorage, AK 99508 Main Line: 907-562-2211 Emergency Room: 907-261-3111

Alaska Native Medical Center 4315 Diplomacy Dr. Anchorage, AK 99508 Main Line: 907-729-1729

Alaska Regional Medical Center

2801 DeBarr Rd. Anchorage, AK 99508 Main Line: 907-276-1131 Emergency Room: 907-264-1232Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 63 SHELL MEDICAL COORDINATOR

Beacon Medical
800 Cordova St. Anchorage, AK 99501 907-222-7612

907-222-6976 fax

DEPARTMENT OF THE INTERIOR

US BOEMRE – Alaska District Main Number: 907-334-5200

Fax: 907-334-2502

Toll Free: 800-764-2627 Regional Director – Jim Kendall Office: 907-334-5200 Regional Supervisor/Fiel d Operations

After Hours:

Jeff Walker Kyle Monkelien Randy Howell Office: 907-334-5300

Fax: 907-334-5302

907-250-0546

907-351-2402

907-382-7814

UNITED STATES COAST GUARD

ENVIRONMENTAL PROTECTION AGENCY National Response Center Washington, D.C. Office: 800-424-8802

Office: 202-267-2675

USCG-Alaska Office: 907-463-2065

Fax: 907-463-2820

Toll Free: 800-424-8802

US Coast Guard Station Office: 907-487-5889

Region 10, Anchorage, Alaska Office

222 W. 7 th Avenue
Suite 19 Anchorage, AK 99513 Office: 907-271-5083

Fax: 907-271-3424

Toll Free: 800-781-0983Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 64 SECTION B-6

KEY PERSONNEL TO REMAIN ABOARD

DURING PARTIAL EVACUATION

Evacuation of personnel from the Discoverer to the evacuation/standby vessel will be conducted using the personnel basket and crane.

This is a suggested list of minimum personnel to remain on location; however, wellsite conditions may dictate that an alternative list be followed.

Qty. Position

1 Vessel Master 2 Shell Drilling Foreman 1 Maintenance Supervisor 1 Electrical Supervisor 1 Mechanical Supervisor

1 Electronics Technician

1 Motorman 1 Medic (SAFETY TECH) 1 Subsea Engineer 2 Senior Toolpusher 2 Toolpushers

2 Drillers

2 Assistant Drillers

4 Floorhands 1 Deck Supervisor

2 Roustabouts
1 Cementer 2 Mud Loggers 1 Mud Engineer 2 Dynamic Safety Technicians 1 Radio Operator 1 Crane Operator

NOTE: Once the emergency is clearly def ined, the above pers onnel should then be

transferred to the evacuation ve ssel if they will not be needed.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 65 

### APPENDIX SECTION C

SECTION C-1



### EQUIPMENT LIST AND INVENTORY

NO. DESCRIPTION 215 30 Minute Pressure demand SCBA w/ Pigtail 50 Hose Line Work Unit w/Escape Cylinder 6 8-Bottle Cascade of Breathing Air 2 8-Bottle Cascade of Breathing Air- Drill Floor 2 2-Bottle Cascade of Breathing Air- Cranes 3 Oxygen Resuscitator w/ Spare Cylinders 1 Breathing Air Compressors

6 Portable H 2 S Monitors Five Gas (H 2 S, LEL, CO, SO 2 , O 2 ) 2 Sensidyne/Gastech Manual Pump Type Detectors

10 Boxes H 2 S Tubes 4L

10 Boxes H 2 S Tubes 4H

10 Boxes SO 2 Tubes 5M 8 Windsock(s) with Pole and Bracket 2 Megaphones (Bullhorn) w/Spare Batteries

4 4’ x 8’ H 2 S Marine Warning Signs 4 2’ x 3’ Red Warning Light Panels 8 Primary and Secondary Safe Briefing Area Signs 2 Flare Pistol 25mm, w/Flares

10 White Marker Boards with Erasers and Markers 4 Flashlights w/ spare batteries 2 Safety harness w/ 150’ Safety Line 2 First Aid Kit, 24 piece 10 Operating Condition Signs for Work Areas

300 Mini Check 1 Air Lab/ Air Quality Test Kit

DETECTION AND ALARM SYSTEMS

NO. DESCRIPTION

1 H 2 S Fixed Monitor w/24 Channel Rack 3 Remote Annunciator Display for Gas Detection (Drill Floor, ECR, Shell Drilling Foreman)

17 H 2 S Sensors for Fixed Monitor 4 Explosion Proof Dual Light/Siren

5 Hazardous Area Alarms

20 Indoor AlarmsHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 66 EVACUATION VESSEL

All personnel will have a self-contained breathing apparatus and H 2 S training.

Vessels will remain upwind or at a safe distance when not in use. Vessels coming alongside will use caution monitori ng with detectors to insure H 2 S or SO 2 is not present. All personnel on the vessel will don SCBAs when approaching a rig to evacuate personnel when H 2 S is present at 20 ppm TWA 15 or SO 2 at 2ppm or greater.

NO. DESCRIPTION

30 30-minute SCBA Units

6 10-minute SCBA work units 15 8-Bottle Cascade of Breathing Air

14 12-Main Manifold

2 Distribution Panels

162 3’ – 5’ Low Pressure Hose Lines

6 50’ Low Pressure Hose Lines

2 100’ Low Pressure Hose Lines

HELICOPTER

Helicopters will not land if red lights are flashing indicating the presence of H 2 S.

Radio communications will be made direct to the drillship to determine if the heliport is

clear from H 2 S and SO 2

.Hydrogen Sulfide Contingency PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc.May 201167SECTION C-2NOBLE DRILLING SUPERINTENDENT’S CHECKLIST: SAFETY EQUIPMENTItemQtyDescriptionOKDateCheckedRemarksOKDateCheckedRemarks1 2 SAFE BRIEFING AREAS2 1 H2S Safety Equipment Package3 N/A Sets MY-6 Warning Flags4 - Zinc Carbonate or Zinc Oxide Equivalent5 - Continuous type H2S detectors as follows:5-1 Aft Quarters5-2 Forward Quarters5-3 Quarters Intake5-4 Engine Room Intake5-5 Sack Room5-6 Bridge Intake5-7 Possum Belly5-8 Mud Return5-9 Trip Tank5-10 Mud Pitts5-11 Pump Room5-12 Driller’s Cabin5-13 Cement Unit5-14 Shale Shaker5-15 Shale Shaker5-16 Bell Nipple5-17 Moon PoolHydrogen Sulfide Contingency PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc.May 201168ItemQtyDescriptionOKDateCheckedRemarksOKDateCheckedRemarks6 N/A Electric fans – Placed as follows:1. Rig Floor2. Shale Shaker Area3. Mud Pit and Storage Area7 1 Forced Air Control Switch in Mudlogging Unit8 - Safety equipment – as specified in inventory lists______ _________ _______ _______** For more information on these safety equipment items, see SectionII, “SAFETY EQUIPMENT”.Hydrogen Sulfide Contingency PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc.May 201169SECTION C-3SAFETY EQUIPMENT CHECKLIST – MUDLOGGERTo be checked and maintained by MudloggerItemQtyDescriptionOKDateCheckedRemarksOKDateCheckedRemarks1 2 Self-contained breathing apparatus for all Mud Loggers2 1 Switch inside the unit that controls the forced air duct into the unit3 1 Multi-gas Detector w/ H2SHydrogen Sulfide Contingency PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc.May 201170SECTION C-4SAFETY EQUIPMENT CHECKLIST – H2S SAFETY TECHNICIANTo be Checked and Maintained by H2S Safety TechnicianItemQtyDescriptionOKDateCheckedRemarksOKDateCheckedRemarks1 All The continuous type monitoring units as described in this plan2 All Breathing Air Cascade System3 All H2S Alarm System as described in this plan4 - Self-contained Breathing Apparatus for all H2S Safety Technicians5 All SCBA for DrillshipHydrogen Sulfide Contingency PlanChukchi Sea, AlaskaShell Gulf of Mexico Inc.May 201171SECTION C-5SAFETY EQUIPMENT CHECKLIST – MUD ENGINEERTo be checked and maintainedBy Mud EngineerItemQtyDescriptionOKDateCheckedRemarksOKDateCheckedRemarks1 1 Self-contained breathing apparatus for all mud engineers2 - 100% zinc basic carbonate orzinc oxide or equivalent3 1 Garrett gas train units4Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 72 SECTION C-6

SHELL CHECKLIST OF ROUTINE DUTIES

Perform each week:

1. Check volume of propane supply for flar e ignitors and make sure lines are not plugged. Light each burner to verify syst em. (Backup ignition will be available)

2. Check all SCBA units for operation: pressure demand regulator, escape bottle air volume, supply bottle air volume.

3. Check breathing equipment mask assemb ly to see that straps are loosened and turned back ready to put on.

4. Check pressure on breathing equipment air bottles to make sure they are charged to

full volume.

5. Check breathing equipment air bottles to make sure all pressure demand regulators are working. This requires that the bottl e is opened and the mask assembly be put on tight enough so that air flows when inhaling. Open one side of mask to be sure air is pressured.

6. Confirm pressure on all air supply bottles.

7. Perform breathing equipment drills with all on-board personnel.

8. Check oxygen resuscitators for pressure in oxygen bottle and make sure demand regulator is working.

9. Check the following supplies for availability:

a. Stretcher b. Spot Check Detectors c. Safety belts and ropes d. Flare gun and flares. e. Emergency telephone lists f. Spare Air bottles g. Spare Oxygen Bottles

h. Detectors and Tubes

10. Test the explosion meter to ve rify that the bat teries are good.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 73 

### SECTION D

RULES AND REGULATIONS

SECTION D-1

30 CFR §250.490 Hydrogen Sulfide Regulations

(a) What precautions must I take when operating in an H 2 S area? You must:

(1) Take all necessary and feasible precautions and measures to protect personnel from the toxic

effects of H 2 S and to mitigate damage to property and the environment caused by H 2 S. You must follow the requirements of this section when conducting drilling, we ll-completion/well-workover, and production operations in zones with H 2 S present and when conducting oper ations in zones where the presence of H 2 S is unknown. You do not need to follow these requirements when operating in

zones where the absence of H 2 S has been confirmed; and

(2) Follow your approved contingency plan.

(b) Definitions. Terms used in this section have the following meanings:

Facility means a vessel, a structure, or an artificial island used for drilling, we ll-completion, wellworkover, and/or production operations.

H 2 S absent means:

(1) Drilling, logging, coring, testing, or prod ucing operations have confirmed the absence of H 2 S in

concentrations that could potentially result in atmospheric conc entrations of 20 ppm or more of H 2 S;

or

(2) Drilling in the surrounding areas and correlation of geological and seismic data with equivalent stratigraphic units have confirmed an absence of H 2 S throughout the area to be drilled.

H 2 S present means that drilling, logging, coring, testing, or produci ng operations have confirmed the presence of H 2 S in concentrations and volumes that could potentially resu lt in atmospheric concentrations of 20 ppm or more of H 2 S.

H 2 S unknown means the designation of a zone or geologic formation where neither the presence

nor absence of H 2 S has been confirmed.

Well-control fluid means drilling mud and completion or workover fluid as appropriate to the particular operation being conducted.

(c) Classifying an area fo r the presence of H 2 S. You must:

(1) Request and obtain an approved classification for the area from the Regional Supervisor before you begin operations. Classifications are “H 2 S absent,” H 2 S present,” or “H 2 S unknown”;

(2) Submit your request with your application for permit to drill;Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 74 (3) Support your request with available information such as geologic and geophysical data and correlations, well logs, formation tests, cores and analysis of formation fluids; and

(4) Submit a request for reclassification of a zone when additional data indicate a different

classification is needed.

(d) What do I do if conditions change? If you encounter H 2 S that could potentially result in atmospheric concentrations of 20 ppm or more in areas not previously classified as having H 2 S present, you must immediately notify BOE a nd begin to follow requir ements for areas with H 2 S
present.

(e) What are the requirements for conducting simultaneo us operations? When conducting any combination of drilling, well-completion, well- workover, and production operations simultaneously, you must follow the requirements in the sect ion applicable to each individual operation.

(f) Requirements for submitting an H 2 S Contingency Plan. Before you begin operations, you must

submit an H 2 S Contingency Plan to the District Manager for approval. Do not begin operations before the District Manager approves your plan. You must keep a copy of the approved plan in the field, and you must follow the plan at all times. Your plan must include:

(1) Safety procedures and rules that you will follow concerning equipment, drills, and smoking;

(2) Training you provide for empl oyees, contractors, and visitors;

(3) Job position and title of the person respon sible for the overall safety of personnel;

(4) Other key positions, how these positions fit into your organization, and what the functions, duties, and responsibilities of t hose job positions are;

(5) Actions that you will take when the concentration of H 2 S in the atmosphere reaches 20 ppm, who will be responsible for those actions, and a descrip tion of the audible and visual alarms to be activated;

(6) Briefing areas where pers onnel will assemble during an H 2 S alert. You must have at least two briefing areas on each facility and use the briefing area that is upwind of the H 2 S source at any given time;

(7) Criteria you will use to decide when to evacuat e the facility and procedures you will use to safely evacuate all personnel from the facility by vessel, capsule, or lifeboat. If you use helicopters during

H 2 S alerts, describe the types of H 2 S emergencies during which you c onsider the risk of helicopter activity to be acceptable and the precaut ions you will take during the flights;

(8) Procedures you will use to safely position all vesse ls attendant to the facility. Indicate where you will locate the vessels with respect to wind direct ion. Include the distance fr om the facility and what procedures you will use to safely relo cate the vessels in an emergency;

(9) How you will provide protective-breathing equipment for all personnel, including contractors and visitors;Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 75 (10) The agencies and facilities you will notify in case of a release of H 2 S (that constitutes an emergency), how you will notify them , and their telephone numbers. Incl ude all facilities that might be exposed to atmospheric concentra tions of 20 ppm or more of H 2 S;

(11) The medical personnel and facilities you will use if needed, their addresses, and telephone numbers;

(12) H 2 S detector locations in production facilities pr oducing gas containing 20 ppm or more of H 2 S.

Include an “H 2 S Detector Location Drawing” showing:

(i) All vessels, flare outlets, wellheads, and ot her equipment handling production containing H 2 S;

(ii) Approximate maximum concentration of H 2 S in the gas stream; and

(iii) Location of all H 2 S sensors included in your contingency plan;

(13) Operational conditions when y ou expect to flare gas containing H 2 S including the estimated maximum gas flow rate, H 2 S concentration, and dur ation of flaring;

(14) Your assessment of the ri sks to personnel during flaring and w hat precautionary measures you will take;

(15) Primary and alternate methods to ignite t he flare and procedures for sustaining ignition and monitoring the status of the flare ( i.e. , ignited or extinguished);

(16) Procedures to shut off t he gas to the flare in the event the flare is extinguished;

(17) Portable or fixed sulphur dioxide (SO 2 )-detection system(s) you will use to determine SO 2 concentration and exposure hazard when H 2 S is burned;

(18) Increased monitoring and warning procedures you will take when the SO 2 concentration in the atmosphere reaches 2 ppm;

(19) Personnel protection measures or evacuat ion procedures you will initiate when the SO 2 concentration in the atmosphere reaches 5 ppm;

(20) Engineering controls to protect personnel from SO 2 ; and

(21) Any special equipment, proc edures, or precautions you will use if you conduct any combination of drilling, well-completion, well-work over, and production operat ions simultaneously.

(g) Training program —(1) When and how often do employees need to be trained? All Shells and contract personnel must complete an H 2 S training program to meet the requirements of this section:

(i) Before beginning wo rk at the facility; and

(ii) Each year, within 1 year after completion of the previous class.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 76 (2) What training documentation do I need? For each individual workin g on the platform, either:

(i) You must have documentation of th is training at the facility where the individual is employed; or

(ii) The employee must carry a training completion card.

(3) What training do I need to give to visitors and employees previously trained on another facility? —(i) Trained employees or contract ors transferred from another facili ty must attend a supplemental briefing on your H 2 S equipment and procedures before begi nning duty at your facility;

(ii) Visitors who will remain on your facility more than 24 hours must receive the training required for employees by paragraph (g)(4) of this section; and

(iii) Visitors who will depart before spending 24 hours on the facility are exempt from the training required for employees, but they must, upon a rrival, complete a briefing that includes:

(A) Information on the location and use of an assi gned respirator; practice in donning and adjusting the assigned respirator; information on the safe briefing areas, alarm system, and hazards of H 2 S

and SO 2 ; and

(B) Instructions on their responsibilities in the event of an H 2 S release.

(4) What training must I provide to all other employees? You must train all individuals on your facility

on the:

(i) Hazards of H 2 S and of SO 2 and the provisions for personnel safety contained in the H 2 S Contingency Plan;

(ii) Proper use of safety equipment which the employee may be required to use;

(iii) Location of protec tive breathing equipment, H 2 S detectors and alarms, ventilation equipment, briefing areas, warning systems, evacuation pr ocedures, and the direction of prevailing winds;

(iv) Restrictions and corrective measures concer ning beards, spectacles, and contact lenses in conformance with ANSI Z88.2, Am erican National Standard for Respiratory Protection (incorporated by reference as specified in §250.198);

(v) Basic first-aid procedures applicable to victims of H 2 S exposure. During all drills and training sessions, you must address procedur es for rescue and first aid for H 2 S victims;

(vi) Location of:

(A) The first-aid kit on the facility;

(B) Resuscitators; and

(C) Litter or other device on the facility.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 77 (vii) Meaning of all warning signals.

(5) Do I need to post safety information? You must prominently post safety information on the facility and on vessels serving the facility ( i.e. , basic first-aid, escape routes, instructions for use of life boats, etc.).

(h) Drills. (1) When and how often do I need to conduct drills on H 2 S safety discussions on the facility? You must:

(i) Conduct a drill for each person at the facility during normal duty hours at least once every 7-day period. The drills must consist of a dry-run performance of personnel activities related to assigned jobs.

(ii) At a safety meeting or other meetings of all personnel, discuss drill performance, new H 2 S

considerations at the facility, and other updated H 2 S information at least monthly.

(2) What documentation do I need? You must keep records of attendance for:

(i) Drilling, well-completion, and well-workover operations at the facility until operations are completed; and

(ii) Production operations at the facility or at the nearest field office for 1 year.

(i) Visual and audible warning systems —(1) How must I install wind direction equipment? You must install wind-direction equipment in a location visible at all times to individuals on or in the immediate vicinity of the facility.

(2) When do I need to display operational danger signs, di splay flags, or activate visual or audible

alarms? —(i) You must display warning signs at all times on facilities with wells capable of producing H 2 S and on facilities that process gas containing H 2 S in concentrations of 20 ppm or

more.

(ii) In addition to the signs, you must activate audi ble alarms and display flags or activate flashing red lights when atmospheric concentration of H 2 S reaches 20 ppm.

(3) What are the requirements for signs? Each sign must be a high-visibility yellow color with black lettering as follows:

Letter height Wording

12 inches Danger.

Poisonous Gas.

Hydrogen Sulfide.

7 inches Do not approach if red flag is flying.

(Use appropriate wording at right) Do not approach if red lights are flashing.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 78 (4) May I use existing signs? You may use existing signs contai ning the words “Danger-Hydrogen

Sulfide-H 2 S,” provided the words “Poisonous Gas. Do No t Approach if Red Flag is Flying” or “Red Lights are Flashing” in lettering of a minimum of 7 inches in height are displayed on a sign immediately adjacent to the existing sign.

(5) What are the requirements fo r flashing lights or flags? You must activate a sufficient number of lights or hoist a sufficient number of flags to be visible to vessels and aircraft. Each light must be of sufficient intensity to be seen by approaching vessels or aircraft any time it is activated (day or night). Each flag must be red, rectangular, a mini mum width of 3 feet, and a minimum height of 2

feet.

(6) What is an audible warning system? An audible warning system is a public address system or siren, horn, or other similar warni ng device with a unique sound used only for H 2 S.

(7) Are there any other requi rements for visual or audible warning devices? Yes, you must:

(i) Illuminate all signs and flags at night and under conditions of poor visibility; and

(ii) Use warning devices that are suitable fo r the electrical classification of the area.

(8) What actions must I take when the alarms are activated? When the warning devices are activated, the designated responsible persons must inform personnel of the level of danger and

issue instructions on the initiation of appropriate protective measures.

(j) H 2 S-detection and H 2 S monitoring equipment —(1) What are the requirements for an H 2 S detection system? An H 2 S detection system must:

(i) Be capable of sensing a minimum of 10 ppm of H 2 S in the atmosphere; and

(ii) Activate audible and visual alarms when the concentration of H 2 S in the atmosphere reaches 20

ppm.

(2) Where must I have sensors for drilling, well-completion, and well-workover operations? You must

locate sensors at the:

(i) Bell nipple;

(ii) Mud-return line receiver tank (possum belly);

(iii) Pipe-trip tank;

(iv) Shale shaker;

(v) Well-control fluid pit area;

(vi) Driller's station;

(vii) Living quarters; andHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 79 (viii) All other areas where H 2 S may accumulate.

(3) Do I need mud sensors? The District Manager may require mud sensors in the possum belly in

cases where the ambient air sensors in the m ud-return system do not consistently detect the presence of H 2 S.

(4) How often must I observe the sensors? During drilling, well-completion and well-workover operations, you must continuously observe the H 2 S levels indicated by the monitors in the work areas during the following operations:

(i) When you pull a wet string of drill pipe or workover string;

(ii) When circulating botto ms-up after a drilling break;

(iii) During cementing operations;

(iv) During logging operations; and

(v) When circulating to condition m ud or other well-control fluid.

(5) Where must I have sensor s for production operations? On a platform where gas containing H 2 S of 20 ppm or greater is produced, processed, or otherwise handled:

(i) You must have a sensor in rooms, buildings, deck areas, or low-laying deck areas not otherwise covered by paragraph (j)(2) of this section, where atmospheric concentrations of H 2 S could reach 20 ppm or more. You must have at least one sensor per 400 square feet of deck ar ea or fractional part of 400 square feet;

(ii) You must have a sensor in buildings where personnel have their living quarters;

(iii) You must have a sensor withi n 10 feet of each vessel, compressor, wellhead, manifold, or pump, which could release enough H 2 S to result in atmospheric concentra tions of 20 ppm at a distance of 10 feet from the component;

(iv) You may use one sensor to detect H 2 S around multiple pieces of equipment, provided the

sensor is located no more than 10 feet from each piece, except that you need to use at least two sensors to monitor compresso rs exceeding 50 horsepower;

(v) You do not need to have sensors near wells that are shut in at the master valve and sealed closed;

(vi) When you determine where to pl ace sensors, you must consider:

(A) The location of system fittings, flanges, valv es, and other devices subject to leaks to the atmosphere; and

(B) Design factors, such as the type of decking and the location of fire walls; andHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 80 (vii) The District Manager may re quire additional sensors or other monitoring capabilities, if warranted by site specific conditions.

(6) How must I functionally test the H 2 S Detectors? —(i) Personnel trained to calibrate the particular H 2 S detector equipment being used must test detectors by exposing them to a known concentration in the range of 10 to 30 ppm of H 2 S.

(ii) If the results of any functional test are not within 2 ppm or 10 per cent, whichever is greater, of the applied concentration, reca librate the instrument.

(7) How often must I test my detectors? —(i) When conducting drilling, drill stem testing, wellcompletion, or well-workover operations in areas classified as H 2 S present or H 2 S unknown, test all detectors at least once every 24 hours. When drilling, begin functional testing before the bit is 1,500 feet (vertically) above the potential H 2 S zone.

(ii) When conducting producti on operations, test all detectors at least every 14 days between tests.

(iii) If equipment requires calibration as a result of two consecutive functi onal tests, the District Manager may require that H 2 S-detection and H 2 S-monitoring equipment be functionally tested and calibrated more frequently.

(8) What documentation must I keep? —(i) You must maintain record s of testing and calibrations (in the drilling or production operations r eport, as applicable) at the facilit y to show the present status and history of each device, includ ing dates and details concerning:

(A) Installation;

(B) Removal;

(C) Inspection;

(D) Repairs;

(E) Adjustments; and

(F) Reinstallation.

(ii) Records must be available for inspection by BOE personnel.

(9) What are the requirements for nearby vessels? If vessels are stationed overnight alongside

facilities in areas of H 2 S present or H 2 S unknown, you must equip vessels with an H 2 S-detection system that activates audible and visual alarms when the concentration of H 2 S in the atmosphere reaches 20 ppm. This requireme nt does not apply to vessels positioned upwind and at a safe distance from the facility in a ccordance with the positioning proc edure described in the approved

H 2 S Contingency Plan.

(10) What are the requirements for nearby facilities? The District Manager may require you to equip nearby facilities with portable or fixed H 2 S detector(s) and to test and calibrate those detectors. ToHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 81 invoke this requirement, the District Manager will consider dispersion modeling results from a possible release to determine if 20 ppm H 2 S concentration levels could be exceeded at nearby

facilities.

(11) What must I do to protect against SO 2 if I burn gas containing H 2 S? You must:

(i) Monitor the SO 2 concentration in the air with portable or st rategically placed fixed devices capable of detecting a minimum of 2 ppm of SO 2 ;

(ii) Take readings at least hourly and at any time personnel detect SO 2 odor or nasal irritation;

(iii) Implement the personnel protecti ve measures specified in the H 2 S Contingency Plan if the SO 2 concentration in the work area reaches 2 ppm; and

(iv) Calibrate devices every 3 months if you us e fixed or portable electronic sensing devices to

detect SO 2

.

(12) May I use alternative measures? You may follow alternative measures instead of those in paragraph (j)(11) of this section if you propose and the R egional Supervisor approves the alternative

measures.

(13) What are the requirements for protective-breathing equipment? In an area classified as H 2 S present or H 2 S unknown, you must:

(i) Provide all personnel, including contractors and visitors on a facility, with immediate access to self-contained pressure-demand-type respirators with hoseline capability and breathing time of at

least 15 minutes.

(ii) Design, select, use, and maintain respirators in conformance with ANSI Z88.2 (incorporated by reference as specified in §250.198).

(iii) Make available at least two voice-transmi ssion devices, which can be used while wearing a respirator, for use by designated personnel.

(iv) Make spectacle kits available as needed.

(v) Store protective-breathing eq uipment in a location that is quickly and easily accessible to all personnel.

(vi) Label all breathing-air bottles as c ontaining breathing-qualit y air for human use.

(vii) Ensure that vessels attendant to facilities carry appropriate protective-breathing equipment for each crew member. The District Manager may require additional protective-b reathing equipment on certain vessels attendant to the facility.

(viii) During H 2 S alerts, limit helicopter flights to and from facilities to the conditions specified in the

H 2 S Contingency Plan. During authorized flights, the flight crew and passengers must use pressure-Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 82 demand-type respirators. You must tr ain all members of flight crews in the use of the particular type(s) of respirator equipment made available.

(ix) As appropriate to the particular operation(s) , (production, drilling, well-completion or wellworkover operations, or any combi nation of them), prov ide a system of breathing-air manifolds, hoses, and masks at the facility and the briefing areas. You must provide a cascade air-bottle system for the breathing-air manifold s to refill individual protective -breathing apparatus bottles. The cascade air-bottle system may be recharged by a hi gh-pressure compressor suitable for providing breathing-quality air, provided the compressor suct ion is located in an uncontaminated atmosphere.

(k) Personnel safety equipment —(1) What additional personnel-safety equipment do I need? You must ensure that your facility has:

(i) Portable H 2 S detectors capable of detecting a 10 ppm concentration of H 2 S in the air available for use by all personnel;

(ii) Retrieval ropes with safety harnesses to re trieve incapacitated pers onnel from contaminated

areas;

(iii) Chalkboards and/or note pads for communication purposes located on the rig floor, shale-shaker area, the cement-pump rooms, well-bay areas, production pr ocessing equipment area, gas compressor area, and pi peline-pump area;

(iv) Bull horns and flashing lights; and

(v) At least three resuscitat ors on manned facilities, and a number equal to the personnel on board, not to exceed three, on normally unmanned facilities, complete with face ma sks, oxygen bottles, and spare oxygen bottles.

(2) What are the requirements for ventilation equipment? You must:

(i) Use only explosion-proof ventilation devices;

(ii) Install ventilation devices in areas where H 2 S or SO 2 may accumulate; and

(iii) Provide movable ventilation devices in work areas. The movable ventilation devices must be multidirectional and capable of dispersing H 2 S or SO 2 vapors away from working personnel.

(3) What other personnel safety equipment do I need? You must have the following equipment readily available on each facility:

(i) A first-aid kit of appropriate size and content for the number of personnel on the facility; and

(ii) At least one litter or an equivalent device.

(l) Do I need to notify MMS in the event of an H 2 S release? You must notify MMS without delay in the event of a gas release which results in a 15-minute time-weighted average atmospheric

concentration of H 2 S of 20 ppm or more anywhere on the OC S facility. You must report these gasHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 83 releases to the District Manager immediately by oral communication, with a written follow-up report within 15 days, pursuant to §§250.188 through 250.190.

(m) Do I need to use special drilling, comple tion and workover fluids or procedures? When working

in an area classified as H 2 S present or H 2 S unknown:

(1) You may use either water- or oil- base muds in accordance with §250.300(b)(1).

(2) If you use water-base well-control fl uids, and if ambient air sensors detect H 2 S, you must immediately conduct either the Garrett-Gas-Train test or a comparable test for soluble sulfides to confirm the presence of H 2 S.

(3) If the concentration detected by air sensors in over 20 ppm, personnel conducting the tests must don protective-breathing equipment conforming to paragraph (j)(13) of this section.

(4) You must maintain on the facility suffici ent quantities of additives for the control of H 2 S, wellcontrol fluid pH, and corrosion equipment.

(i) Scavengers. You must have scavengers for control of H 2 S available on the facility. When H 2 S is detected, you must add scavengers as needed. You must suspend drilling until the scavenger is circulated throughout the system.

(ii) Control pH. You must add additives for the control of pH to water-base well-control fluids in sufficient quantities to maintain pH of at least 10.0.

(iii) Corrosion inhibitors. You must add additives to the well-c ontrol fluid system as needed for the

control of corrosion.

(5) You must degas well-control fluids containing H 2 S at the optimum location for the particular facility. You must collect the gases removed and burn them in a closed flare system conforming to paragraph (q)(6) of this section.

(n) What must I do in the event of a kick? In the event of a kick, you must use one of the following alternatives to dispose of the well-influx fluids giving consideration to personnel safety, possible environmental damage, and possible facility well-equip ment damage:

(1) Contain the well-fluid influx by shutting in the well and pumping the fluids back into the formation.

(2) Control the kick by using appropria te well-control techniques to prev ent formation fracturing in an open hole within the pressure limits of the well equipme nt (drill pipe, work string, casing, wellhead, BOP system, and related equipment). The disposal of H 2 S and other gases must be through pressurized or atmospheric mud-separator equipm ent depending on volume, pressure and

concentration of H 2 S. The equipment must be designed to re cover well-control fluids and burn the gases separated from the well-control fluid. The well-control fluid must be treated to neutralize H 2 S and restore and maintain the proper quality.

(o) Well testing in a zone known to contain H 2 S. When testing a well in a zone with H 2 S present, you must do all of the following:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 84 (1) Before starting a well test, conduct safety meet ings for all personnel who will be on the facility during the test. At the meetings , emphasize the use of protective-breathing equipment, first-aid procedures, and the Contingency Plan. Only competent personnel w ho are trained and are knowledgeable of the haz ardous effects of H 2 S must be engaged in these tests.

(2) Perform well testing with the mi nimum number of personnel in the immediate vicinity of the rig floor and with the appropriate test equipment to sa fely and adequately perform the test. During the test, you must continuously monitor H 2 S levels.

(3) Not burn produced gases except through a flar e which meets the requi rements of paragraph (q)(6) of this section. Befo re flaring gas containing H 2 S, you must activate SO 2 monitoring equipment in accordance with paragraph (j)(11) of this section. If you detect SO 2 in excess of 2 ppm, you must implement the personnel protective measures in your H 2 S Contingency Plan, required by paragraph (f) of this sect ion. You must also follow the requi rements of §250.1105. You must pipe gases from stored test fluids in to the flare outlet and burn them.

(4) Use downhole test tools and wellhead equipment suitable for H 2 S service.

(5) Use tubulars suitable for H 2 S service. You must not use drill pi pe for well testing without the prior approval of the District Manager. Water cushions mu st be thoroughly inhibited in order to prevent

H 2 S attack on metals. You must flush the test string fluid treated for this purpos e after completion of

the test.

(6) Use surface test units and rela ted equipment that is designed for H 2 S service.

(p) Metallurgical properties of equipment. When operating in a zone with H 2 S present, you must use equipment that is constructed of ma terials with metallurgical properties that resist or prevent sulfide stress cracking (also known as hydrogen embri ttlement, stress corrosion cracking, or H 2 S embrittlement), chloride-stress cracking, hydrogen-induced cracking, and other failure modes. You must do all of the following:

(1) Use tubulars and other equipment, casing, tubing, drill pipe, couplings, flanges, and related equipment that is designed for H 2 S service.

(2) Use BOP system components, wellhead, pr essure-control equipment, and related equipment exposed to H 2 S-bearing fluids in conformance with NACE Standard MR0175–03 (incorporated by reference as specified in §250.198).

(3) Use temporary downhole well-security devices su ch as retrievable packers and bridge plugs that are designed for H 2 S service.

(4) When producing in zones bearing H 2 S, use equipment constructed of materials capable of resisting or preventing sulfide stress cracking.

(5) Keep the use of welding to a minimum during the installation or modification of a production facility. Welding must be done in a manner that ensures resistance to sulfide stress cracking.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 85 (q) General requirements when operating in an H 2 S zone —(1) Coring operations. When you conduct coring operations in H 2 S-bearing zones, all personnel in the working area must wear protective-breathing equipment at least 10 stands in advance of retrieving the core barrel. Cores to be transported must be sealed a nd marked for the presence of H 2 S.

(2) Logging operations. You must treat and condition well-control fluid in use for logging operations

to minimize the effects of H 2 S on the logging equipment.

(3) Stripping operations. Personnel must monitor displaced well-control fluid returns and wear protective-breathing equipment in the working area when the at mospheric concentration of H 2 S reaches 20 ppm or if the well is under pressure.

(4) Gas-cut well-control fluid or well kick from H 2 S-bearing zone. If you decide to circulate out a kick, personnel in the working area during botto ms-up and extended-kill op erations must wear protective-breathing equipment.

(5) Drill- and workover-string design and precautions. Drill- and workover-strings must be designed consistent with the anticipated de pth, conditions of the hole, and reservoir environment to be encountered. You must minimize exposure of the dr ill- or workover-string to high stresses as much as practical and consistent wit h well conditions. Pr oper handling techniques must be taken to minimize notching and stress conc entrations. Precautions must be taken to minimize stresses caused by doglegs, improper stiffness ratios, impr oper torque, whip, abrasive wear on tool joints, and joint imbalance.

(6) Flare system. The flare outlet must be of a diameter that allows easy nonrestricted flow of gas.

You must locate flare line outlets on the downside of the facility and as far fr om the facility as is feasible, taking into account the prevailing wind directions, the wake effects caused by the facility and adjacent structure(s), and the hei ght of all such facilities and structures. You must equip the flare outlet with an automatic igni tion system including a pilot-light gas source or an equivalent system. You must have alternate methods for igniti ng the flare. You must pipe to the flare system

used for H 2 S all vents from production process equipment, tanks, relief valves, burst plates, and

similar devices.

(7) Corrosion mitigation. You must use effective means of monitoring and controlling corrosion caused by acid gases (H 2 S and CO 2 ) in both the downhole and surfac e portions of a production system. You must take specific corrosion monitori ng and mitigating measures in areas of unusually

severe corrosion where accumulation of water and/or higher concentration of H 2 S exists.

(8) Wireline lubricators. Lubricators which may be exposed to fluids containing H 2 S must be of H 2 Sresistant materials.

(9) Fuel and/or instrument gas. You must not use gas containing H 2 S for instrument gas. You must not use gas containing H 2 S for fuel gas without the prior approval of the District Manager.

(10) Sensing lines and devices. Metals used for sensing line and safety-control devices which are necessarily exposed to H 2 S-bearing fluids must be constructed of H 2 S-corrosion resistant materials

or coated so as to resist H 2 S corrosion.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 86 (11) Elastomer seals. You must use H 2 S-resistant materials for all s eals which may be exposed to fluids containing H 2 S.

(12) Water disposal. If you dispose of produced water by means other than subsurface injection, you must submit to the District Manager an analysis of the anticipated H 2 S content of the water at the final treatment vessel and at the discharge point. T he District Manager may requi re that the water be

treated for removal of H 2 S. The District Manager may require the submittal of an updated analysis if the water disposal rate or the potential H 2 S content increases.

(13) Deck drains. You must equip open deck drains with traps or similar devices to prevent the escape of H 2 S gas into the atmosphere.

(14) Sealed voids. You must take precautions to eliminate sealed spaces in piping designs (e.g., slip-on flanges, reinforcing pads) which can be invaded by atomic hydrogen when H 2 S is present.

[62 FR 3795, Jan. 27, 1997. Redesignated and amended at 63 FR 29479, 29485, May 29, 1998; 65 FR 15864, Mar. 24, 2000. Redesignated and amended at 68 FR 8423, 8434, Feb. 20, 2003; 71 FR 19645, Apr. 17, 2006; 72 FR 12096, Mar. 15, 2007; 72 FR 25201, May 4, 2007]Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 87 SECTION D-2

HYDROGEN SULFIDE PINC LIST

This Section Pertains to Areas Classified as H 2 S Present and H 2 S Unknown.

Definitions: H 2 S present means that drilling, logging, cori ng, testing, or producing operations have confirmed the presence of H 2 S in concentrations and volumes that could potentially result in atmospheric concentrations of 20 ppm or more of H 2 S.

H 2 S unknown means the designation of a zone or geological formation where neither the presence nor absence of H 2 S has been confirmed.

H-100
IS A COPY OF THE APPROVED H 2 S CONTINGENCY PLAN AVAILABLE IN THE FIELD AREA,

AND IS THAT PLAN BEING FOLLOWED? Authority: 490(f)

Enforcement Action: W/S

INSPECTION PROCEDURE: Verify that an approved plan is available and being followed at the facility at the commencement of and throughout all operati ons during which the H 2 S Contingency Plan is in effect.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if an H 2 S Contingency Plan is not available. Issue a facility shut-in ( S ) INC if there is not an approved pl an or the plan is not being followed.

INSPECTION FORM: Enter one item checked per facility.

H-101
ARE AT LEAST TWO SAFE BRIEFING AREAS ESTABLISHED? Authority: 490(f)(6)

Enforcement Action: S

INSPECTION PROCEDURE: 1. Verify that designated safe briefing areas at the facility are as designated in the approved H 2 S Contingency Plan. 2. Verify that designated safe briefing area during the inspection period is upwind of operations.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if safe briefing areas: 1. Are not as approved,

2. Have not been es tablished, or 3. During inspection, is not upwind of operations.

INSPECTION FORM: Enter one item checked per facility.

H-102
ARE ALL PERSONNEL INFORMED OF THE HAZARDS OF H 2 S AND OF SO 2 RESULTING

FROM BURNING H 2 S, AND INSTRUCTED IN THE PROVISIONS FOR PERSONNEL SAFETY

CONTAINED IN THE H 2 S CONTINGENCY PLAN? Authority: 490(g)(4)(i)

Enforcement Action: CHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 88 490(j)(11)(iii)

INSPECTION PROCEDURE: Inspect training session records to verify that personnel were instructed and informed as required.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC to remove any pers on from the facility that has not received the required instructions.

INSPECTION FORM: Enter one item checked per facility.

H-103
ARE ALL PERSONNEL INSTRUCTED IN THE USE OF SAFETY EQUIPMENT WHICH THEY
MAY BE REQUIRED TO USE? Authority: 490(g)(4)(ii)

Enforcement Action: C

INSPECTION PROCEDURE: Inspect training session records to verify that all personnel were inst ructed and informed as required.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC to remove any personnel from the facility that have not received the required instructions.

INSPECTION FORM: Enter one item checked per facility.

H-104
ARE ALL PERSONNEL INFORMED OF THE LOCATION OF PROTECTIVE-BREATHING EQUIPMENT, H 2 S DETECTORS AND ALARMS, VENTIL ATION EQUIPMENT, BRIEFING AREAS, WARNING SYSTEMS, EVACUATION PR OCEDURES, AND THE DIRECTION OF THE

PREVAILING WINDS? Authority: 490(g)(4)(iii)

Enforcement Action: C

INSPECTION PROCEDURE: Inspect training session records to verify that all personnel were inst ructed and informed as required.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC to remove any personnel from the facility that has not received the required instructions.

INSPECTION FORM: Enter one item checked per facility.

H-105
ARE ALL PERSONNEL INFORMED OF TH E RESTRICTIONS AND CORRECTIVE MEASURES CONCERNING BEARDS, SPECTACLES, AND CONTACT LENSES IN CONFORMANCE WITH

ANSI Z88.2? Authority: 198(e)

Enforcement Action: C 490(g)(4)(iv)

INSPECTION PROCEDURE:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 89 Inspect training session records to verify that all personnel were inst ructed and informed as required.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC to remove any personnel from the facility that have not received the required instructions.

INSPECTION FORM: Enter one item checked per facility.

H-106
IS SAFETY INFORMATION PROMINEN TLY POSTED ON THE FACILITY? Authority: 490(g)(5)

Enforcement Action: W

INSPECTION PROCEDURE: Visually observe the facility to veri fy the posting of safety information.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if safety information is not prominently posted on the facility.

INSPECTION FORM: Enter one item checked per facility.

H-107
IS SAFETY INFORMATION PROMINENTLY PO STED ON VESSELS SERVING THE FACILITY? Authority: 490(g)(5)

Enforcement Action: W

INSPECTION PROCEDURE: Visually inspect the vessel to verify the posting of safety information.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if safety information is not prom inently posted on vessels serving the facility.

INSPECTION FORM:

Enter one item checked for each vessel inspected.

H-108
DO ALL SHELL AND CONTRACT PERSONNEL RECEIVE A TRAINING SESSION BEFORE

BEGINNING WORK AT THE FACI LITY AND AGAIN WITHIN 1 YEAR AFTER COMPLETION

OF THE PREVIOUS CLASS? Authority: 490(g)(1)(i)

Enforcement Action: C 490(g)(1)(ii)

INSPECTION PROCEDURE: 1. Verify that all Shell and contract personnel arrivi ng at the facility have received a training session before beginning work. 2. Verify that the Shell and contract personnel have again received that trai ning within 1 year after completion of the previous class.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if, during the inspection, the inspector observes any Shell or contract personnel arriving at the facility who does not receive a training session before beginning work or has not received that training within 1 y ear after completion of the previous class.

INSPECTION FORM:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 90 Enter one item checked per facility.

H-109
DOES EACH PERSON PARTICIPATE IN A DRI LL DURING NORMAL DUTY HOURS AT LEAST

ONCE EVERY 7-DAY PERIOD? Authority: 490(h)(1)(i)

Enforcement Action: W/C

INSPECTION PROCEDURE: Verify that all personnel have participated in a dr ill during normal duty hours at least once in every 7- day period after duty begins.

Note: Duty begins upon arrival at the facility.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records do not indicate that any person(s) did not part icipate in a drill at least once in every 7-day period after duty began. Issue a component shut-in ( C ) INC if individual personnel has not participated in a drill during normal duty hours at least once every 7-day period.

INSPECTION FORM: Enter one item checked per facility.

H-111
ARE RECORDS OF ATTENDANCE FOR TRAINING MAINTAINED AT THE FACILITY OR

DOES THE EMPLOYEE CARRY A T RAINING COMPLETION CARD? Authority: 490(g)(2)(i)

Enforcement Action: W 490(g)(2)(ii)

INSPECTION PROCEDURE: Request to see the records of attendance at the weekly drills and training sessions.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if:

1. The records are not available. 2. The records are incomplete.

INSPECTION FORM: Enter one item checked per facility.

H-113 IS A FIRST-AID KIT, OF A PPROPRIATE SIZE AND CONTENT, READILY AVAILABLE FOR THE
NUMBER OF PERSONNEL ON THE FACILITY? Authority: 490(k)(3)(i)

Enforcement Action: W

INSPECTION PROCEDURE: Visually inspect the facility to verify that a firs t-aid kit of appropriate si ze and content is readily

available.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if:

1. There is no first-aid kit.

2. The first-aid kit is of in sufficient size or content. 3. The first aid kit is not readily available.

INSPECTION FORM:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 91 Enter one item checked for each kit inspected.

H-114
ARE THERE AT LEAST THREE RESUSCITATOR S ON MANNED FACILI TIES, AND A NUMBER EQUAL TO THE PERSONNEL ON BOARD, NO T TO EXCEED THREE, ON NORMALLY UNMANNED FACILITIES (COMPLETE WITH F ACE MASKS, OXYGEN BOTTLES, SPARE OXYGEN BOTTLES) AND ARE THESE ITEMS READILY AVAILABLE? Authority: 490(k)(1)(v)

Enforcement Action: C

INSPECTION PROCEDURE: 1. Visually inspect the facility to verify that at least three resuscitators complete with a face mask and oxygen bottle are available. 2. Visually inspect the facility to verify that spare oxygen bottles are readily available.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( C ) INC if: 1. The facility is not equipped with at least thr ee resuscitators complete with face masks and oxygen

bottles. 2. The facility does not have spare oxygen bottles. 3. The resuscitators and oxygen bottl es are not readily available.

INSPECTION FORM: Enter one item checked per facility.

H-115
IS THERE AT LEAST ONE LITTER OR AN EQ UIVALENT DEVICE ON THE FACILITY AND

READILY AVAILABLE FOR USE? Authority: 490(k)(3)(ii)

Enforcement Action: W

INSPECTION PROCEDURE: Visually inspect the facility to verify that there is at least one litter or an equivalent device readily available on the facility.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if there is not at least one litter or an equivalent device readily available.

INSPECTION FORM: Enter one item checked per facility.

H-117
IS WIND-DIRECTION EQUIPMENT INSTALLED IN LOCATIONS VISIBLE AT ALL TIMES TO

INDIVIDUALS ON OR IN THE IMMEDI ATE VICINITY OF THE FACILITY? Authority: 490(i)(1)

Enforcement Action: S

INSPECTION PROCEDURE: Visually verify that visible wind-direction equipment has been installed at prominent locations. Wind direction equipment includes wi ndsocks, flags, and streamers.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if wind-direction equipment is not visible or has not been installed in prominent locations.

INSPECTION FORM: Enter one item checked per facility.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 92 H-118
ARE OPERATIONAL DANGER SIGNS DISPLAYED AT ALL TIMES ON FACILITIES WITH

WELLS CAPABLE OF PRODUCING H 2 S GAS IN CONCENTRATIONS OF 20 PPM OR MORE? Authority: 490(i)(2)(i)

Enforcement Action: W

INSPECTION PROCEDURE: Inspect the signs and flags to verify that installation is as required. Signs shall : 1. Be installed on each side of the facility.

2. Be a minimum width of 8 feet and a minimum height of 4 feet. 3. Be a high visibility yellow color with black lettering a minimum of 12 inches in height.

4. Read "DANGER - HYDROGEN SULFIDE - H 2 S". 5. Be illuminated at night and under conditions of poor visibility. 6. Be displayed when concentrations of H 2 S reach 20 ppm. Red Flags shall : 1. Be visible to aircraft and watercraft when hoisted.

2. Be a minimum width of 3 feet and a minimum height of 2 feet. 3. Be illuminated at night and under c onditions of poor visibility, and 4. Be displayed when concentrations of H 2 S reach 50 ppm.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if: 1. Signs or flags are not displayed as required. 2. Signs or flags are not available for use.

INSPECTION FORM: Enter one item checked per facility.

H-120
DOES THE FACILITY HAVE AN H 2 S-DETECTION AND H 2 S-MONITORING SYSTEM WHICH IS

CAPABLE OF SENSING A MINIMUM OF 10 PPM H 2 S AND WHICH ACTIVATES AUDIBLE AND

VISUAL ALARMS WHEN THE ATMOSPHERIC CONCENTRATION REACHES 20 PPM AND

ARE THESE SENSING DEVICE S LOCATED AT THE BELL NIPPLE, MUD RETURN LINE RECEIVER TANK (POSSUM BELLY), PIPE TR IP TANK, SHALE SHAKER, WELL-CONTROL FLUID PIT AREA, DRILLER'S STATION, LIVI NG QUARTERS, AND OTHER AREAS WHERE

H 2 S MIGHT ACCUMULATE? Authority: 490(j)(1)(i)

Enforcement Action: S 490(j)(2)(i) 490(j)(2)(ii) 490(j)(2)(iii) 490(j)(2)(iv) 490(j)(2)(v) 490(j)(2)(vi) 490(j)(2)(vii) 490(j)(2)(viii)

INSPECTION PROCEDURE: 1. Visually verify that detection and monito ring equipment (sensors) is installed at: A. Bell nipple.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 93 B. Mud return line receiver tank (possum belly). C. Pipe trip tank.

D. Shale shaker. E. Well-control fluid pit area.

F. Driller’s station. G. Living quarters (drilling personnel).

H. Other areas where H 2 S may accumulate. 2. Have Shell test equipment for operation.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if H 2 S detection and monitoring equipment is not:

1. Installed at the required locations. 2. Operable.

INSPECTION FORM: Enter one item checked for each location inspected.

H-121 ARE SENSORS LOCATED IN ROOMS, BUILDIN GS, DECK AREAS, OR LOW-LAYING DECK

AREAS NOT OTHERWISE COVER ED BY 30 CFR 250.490(j)? Authority: 490(j)(5)(i)

Enforcement Action: S

INSPECTION PROCEDURE: Verify that sensors are locat ed in rooms, buildings, deck areas , or low-laying deck areas not

otherwise covered by 30 CFR 250.490(j).

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if sensors are not located in rooms, buildings, deck areas, or lowlaying deck

areas not otherwise cover ed by 30 CFR 250.490(j).

INSPECTION FORM: Enter one item checked for each location inspected.

H-122
IS AT LEAST ONE SENSOR INSTALLED PER 400 SQUARE FEET OF DECK AREA OR FRACTIONAL PART THEREOF (OR AS OT HERWISE APPROVED BY THE DISTRICT SUPERVISOR)? Authority: 490(j)(5)(i)

Enforcement Action: S

INSPECTION PROCEDURE: Verify that there is at least one sensor installed per 400 square feet of deck area or fractional part thereof (or as otherwise approved by t he District Supervisor).

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if there is not at least one sensor installed per 400 square feet of deck

area or a fractional part thereof (or as otherwise approved by the District Supervisor).

INSPECTION FORM:

Enter one item checked fo r each area inspected.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 94 H-123
IS A SENSOR LOCATED IN BUILDINGS WHERE PERSONNEL HAVE THEIR LIVING
QUARTERS? Authority: 490(j)(5)(ii)

Enforcement Action: S

INSPECTION PROCEDURE: Verify that a sensor is located in buildi ngs where personnel have t heir living quarters.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if there is not a sensor loca ted in buildings where personnel have their living quarters.

INSPECTION FORM: Enter one item checked for each building inspected.

H-124 IS ONE SENSOR LOCATED WITHIN 10 FEET OF EACH VESSEL, COMPRESSOR, WELLHEAD, MANIFOLD, OR PUMP (OR AS OTHERWISE AP PROVED BY THE DIST RICT SUPERVISOR)? Authority: 490(j)(5)(iii)

Enforcement Action: C

INSPECTION PROCEDURE: Inspect to verify that there is one sensor loca ted within 10 feet of each vessel, compressor, wellhead, manifold, or pump (or as otherwis e approved by the Dis trict Supervisor).

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if a sensor is not locat ed within 10 feet of each vessel, compressor, wellhead, manifold, or pump (or as otherwise approved by the District Supervisor).

INSPECTION FORM: Enter one item checked for each component inspected.

H-125
IF ONE SENSOR IS USED TO COVER MULTIPL E PIECES OF EQUIPM ENT, IS EACH PIECE
OF EQUIPMENT NO MORE THAN 10 FEET FROM THE SENSOR (OR AS OTHERWISE APPROVED BY THE DISTRICT SUPERVISOR)? Authority: 490(j)(5)(iv)

Enforcement Action: C

INSPECTION PROCEDURE: Verify that if one sensor is used to cover multip le pieces of equipment, each piece of equipment is

no more than 10 feet from the se nsor (or as otherwise approved by the District Supervisor).

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if pieces of the equipment are more than 10 feet from the sensor (or as otherwise approved by the District Supervisor).

INSPECTION FORM: Enter one item checked for multiple pieces of equipment inspected.

H-126
IS THE H 2 S-DETECTION SYSTEM RECALIBRATED WHEN FUNCTIONAL TESTS ARE NOT WITHIN 2 PPM OR 10 PERCENT, WHICH EVER IS GREATER, OF THE APPLIED CONCENTRATIONS (OR AS OTHERWISE APPROV ED BY THE DISTRICT SUPERVISOR)? Authority: 490(j)(6)(ii)

Enforcement Action: CHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 95 INSPECTION PROCEDURE: Check Shell's records to verify that the H 2 S-detection and H 2 S-monitoring equipment is recalibrated as required (or as otherwise approv ed by the District Supervisor).

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC on the monitored area if the H 2 S-detection and H 2 S-monitoring equipment has not been recalibrated as requir ed (or as otherwise approved by the District Supervisor).

INSPECTION FORM: Enter one item checked per facility.

H-127

ARE PORTABLE H 2 S DETECTORS CAPABLE OF DETECTING 10 PPM CONCENTRATIONS

OF

H 2 S GAS IN AIR AND AVAILABLE FOR USE BY ALL PERSONNEL? Authority: 490(k)(1)(i)

Enforcement Action: W

INSPECTION PROCEDURE: Verify that portable H 2 S detectors capable of detecting 10 ppm concentrations of H 2 S gas in air are available for use by all personnel.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if portable H 2 S detectors are not capable of detecting 10 ppm

concentrations of H 2 S gas in air and available for use by all personnel.

INSPECTION FORM:

Enter one item checked for each portable detector checked.

H-128
ARE PRESSURE-DEMAND TYPE RESPIRATOR S WITH HOSELINE CAPABILITY AND

BREATHING TIME OF AT LEAST 15 MINUTES I MMEDIATELY AVAILABLE AND EASILY

ACCESSIBLE TO ALL PERSONNEL ON THE FACILI TY INCONFORMANCE WITH ANSI Z88.2? Authority: 490(j)(13)(i)

Enforcement Action: S 490(j)(13)(ii) 490(j)(13)(v)

INSPECTION PROCEDURE: 1. Inspect the facility to verify that all pressure -demand type respirators with hoseline capability and breathing time of at least 15 minutes are availa ble and easily accessible to all personnel on the facility and in conformanc e with ANSI Z88.2. 2. Visually inspect gauges to verify that the air t anks are full.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if all pressure-demand type respir ators with hoseline capability of at least 15 minutes of breathing time are not a ccessible to all personnel on the facility and in

conformance with ANSI Z88.2.

INSPECTION FORM: Enter one item checked per facility.

H-129
ARE AT LEAST TWO VOICE TRANSMISSION DEVICES, WHICH CAN BE USED WHILE WEARING A RESPIRATOR, AVAILABLE FOR USE BY DESIGNATED PERSONNEL?Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 96 Authority: 490(j)(13)(iii)

Enforcement Action: W

INSPECTION PROCEDURE: Verify that at least two voice transmission device s, which can be used while wearing a respirator, are available for use by designated personnel.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if there are not at least two voic e transmission devices on the facility.

INSPECTION FORM: Enter one item checked per facility.

H-131
IS EACH BREATHING-AIR BOTTLE LABELED AS CONTAINING BREATHING-QUALITY AIR

FOR HUMAN USE? Authority: 490(j)(13)(vi)

Enforcement Action: C/S

INSPECTION PROCEDURE: Visually inspect the breathing-air bottles to verify that they ar e labeled as containing breathingquality air for human use.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if a few of the br eathing-air bottles are not labeled as containing breathing-quality air for human us e but have ample supply of bottles that are labeled. Issue a facility shut-in ( S ) INC if none of the br eathing-air bottles are labeled as containing breathing-quality ai r for human use.

INSPECTION FORM: Enter one item checked for each bottle inspected.

H-132
DO VESSELS ATTENDANT TO F ACILITIES CARRY APPROPRIATE
PROTECTIVE-BREATHING EQUIPM ENT FOR EACH CREW MEMBER? Authority: 490(j)(13)(vii)

Enforcement Action: C

INSPECTION PROCEDURE: 1. If conditions permit, inspect each attendant vessel to verify that it carri es sufficient protectivebreathing equipment for each crew member. 2. If the District Supervisor has required additional protective-breat hing equipment for vessels, verify that the additional equ ipment is on board.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC to remove the vessel if: 1. The vessel does not carry sufficient protecti ve-breathing equipment fo r each crew member. 2. The vessel does not carry t he additional equipment required by the District Supervisor.

INSPECTION FORM:

Enter one item checked for each vessel inspected.

H-133
FOR AUTHORIZED FLIGHTS DURING H 2 S ALERTS, ARE HELICOPTER FLIGHTS TO AND

FROM THE FACILITY LIMITED TO THE CONDITIONS SPECIFIED IN THE H 2 S CONTINGENCY

PLAN?Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 97 Authority: 490(j)(13)(viii)

Enforcement Action: C

INSPECTION PROCEDURE: Review contingency plans to determine when a fli ght is considered an authorized flight.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if unauthorized flight s are witnessed during an H 2 S alert.

INSPECTION FORM: Enter one item checked for each unauthorized flight.

H-134 DURING AUTHORIZED FLIGHTS, DO TH E FLIGHT CREW AND PASSENGERS USE

PRESSURE-DEMAND TYPE RESPIRATORS? Authority: 490(j)(13)(viii)

Enforcement Action: C

INSPECTION PROCEDURE: During an authorized H 2 S alert flight, observe if the flig ht crew and passengers use pressuredemand type respirators.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if the crew and passengers are not using pressure-demand type respirators.

INSPECTION FORM: Enter one item for each crew member and passenger inspected.

H-135
ARE ALL MEMBERS OF THE FLIGHT CREW TRAINED IN THE USE OF THE PARTICULAR TYPE(S) OF RESPIRATOR EQUI PMENT MADE AVAILABLE? Authority: 490(j)(13)(viii)

Enforcement Action: C

INSPECTION PROCEDURE: Verify that all members of t he flight crew have been trained in the use of the particular type equipment aboard the aircraft or stored at the heliport.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC to remove the helicopter if a ll members of the flight crew have not been trained in the use of the equipment.

INSPECTION FORM: Enter one item checked for each flight crew inspected.

H-136
AS APPROPRIATE TO THE PARTICULAR OPERATION(S), (PRODUCTION, DRILLING, WELL-COMPLETION/WORKOVER, OR ANY COMB INATION THEREOF), IS A SYSTEM OF BREATHING-AIR MANIFOLDS, HOSES, AND MASK S PROVIDED ON THE FACILITY AND IN

THE BRIEFING AREAS? Authority: 490(j)(13)(ix)

Enforcement Action: S

INSPECTION PROCEDURE: Visually inspect the facility, including the briefi ng areas, to verify that a system of breathing-air manifolds, hoses, and masks has been installed as approved in the H 2 S Contingency Plan.

IF NONCOMPLIANCE EXISTS:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 98 Issue a facility shut-in ( S ) INC if a system of breathing-air manifolds, hoses, and masks has not been installed as approved in the H 2 S Contingency Plan.

INSPECTION FORM: Enter one item checked per facility.

H-137
IS A CASCADE AIR-BOTTLE SYSTEM PROVIDED FOR THE BREATHING-AIR MANIFOLDS

AND TO REFILL INDIVIDUAL PROTECTIVE -BREATHING APP ARATUS BOTTLES? Authority: 490(j)(13)(ix)

Enforcement Action: S

INSPECTION PROCEDURE: Visually inspect the facility to verify that the cascade air-bottle system has been installed as approved in the H 2 S Contingency Plan.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if a cascade air-bottle system has not been installed as approved in

the H 2 S Contingency Plan.

INSPECTION FORM: Enter one item checked per facility.

H-138
IF THE CASCADE AIR-BOTTLE SYSTEM IS RECHARGED BY A HIGH-PRESSURE COMPRESSOR SUITABLE FOR PROVIDING BREATHING-QUALITY AIR, IS THE

COMPRESSOR SUCTION LOCATED IN AN UNCONTAMINATED ATMOSPHERE? Authority: 490(j)(13)(ix)

Enforcement Action: S

INSPECTION PROCEDURE: Visually inspect the comp ressor to verify that: 1. It is suitable for prov iding breathing- quality air. 2. The compressor suction is locat ed in an uncontaminated atmosphere.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if: 1. The high-pressure compressor is not suit able for providing breat hing-quality air, or 2. The compressor suction is locat ed in a contaminated atmosphere.

INSPECTION FORM: Enter one item checked per facility.

H-140
ARE RETRIEVAL ROPES WITH SAFETY HARNESSES AVAILABLE TO RETRIEVE

INCAPACITATED PERSONNEL FROM CONTAMINATED AREAS? Authority: 490(k)(1)(ii)

Enforcement Action: W

INSPECTION PROCEDURE: Visually inspect the facility to verify that retr ieval ropes with safety harnesses are available as approved in the H 2 S Contingency Plan.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if retrieval ropes with safety harnesses are not available.

INSPECTION FORM: Enter one item checked per facility.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 99 H-141
ARE CHALKBOARDS AND/OR NOTE PADS AV AILABLE FOR COMMUNICATION PURPOSES LOCATED ON THE RIG FLOOR, SHALE-SH AKER AREA, THE CEMENT-PUMP ROOMS, WELL-BAY AREAS, PRODUCTION PROCESSING EQUIPMENT AREA, GAS COMPRESSOR AREA, AND PIPELINE-PUMP AREA? Authority: 490(k)(1)(iii)

Enforcement Action: W

INSPECTION PROCEDURE: Visually inspect to verify that chalkboards and/or note pads are available at the following locations as approved in the H 2 S Contingency Plan: 1. Rig floor.

2. Shale-shaker area. 3. Cement-pump rooms. 4. Well-bay areas. 5. Production processi ng equipment area. 6. Gas compressor area. 7. Pipeline-pump area.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if chalkboards and/or note pads are not available at the required locations.

INSPECTION FORM: Enter one item checked for each location inspected.

H-142
ARE BULL HORNS AND FLASHING LIGHTS AVAILABLE? Authority: 490(k)(1)(iv)

Enforcement Action: S

INSPECTION PROCEDURE: Visually inspect the facility to verify that t he following equipment is available and operable as approved in the H 2 S Contingency Plan:

Bull horns. Flashing lights.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if operable bull horns and fl ashing lights are not available.

INSPECTION FORM: Enter one item checked per facility.

H-143
ARE AUDIBLE ALARMS AND DISPLAY FLAGS OR FLASHING RED LIGHTS AVAILABLE

FOR USE ON FACILITIES WHEN ATMOSPHERIC CONCENTRATIONS OF H 2 S REACH 20

PPM AND ARE SIGNS AND FLAGS CAPABLE OF BEING ILLUMINATED AT NIGHT AND

UNDER CONDITIONS OF POOR VISIBILITY? Authority: 490(i)(2)(ii)

Enforcement Action: S 490(i)(5) 490(i)(7)(i)

INSPECTION PROCEDURE: Test and visually inspect:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 100 1. Audible alarms 2. Display flags or flashing red lights 3. Signs and flags capable of being illuminated at night and under conditions of poor visibility.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if the above items are not av ailable for use on the facility.

INSPECTION FORM: Enter one item checked per facility.

H-144
ARE ALL VENTILATION DEVICES EXPLOSION -PROOF AND SITUATED IN AREAS WHERE

H 2 S OR SO 2 MAY ACCUMULATE? Authority: 490(k)(2)(i)

Enforcement Action: C/S 490(k)(2)(ii)

INSPECTION PROCEDURE: 1. Visually inspect all ventilation devices to verify that they are explosion-proof. 2. Visually inspect the facility to verify that ventilation devices are situated in areas where H 2 S and

SO 2 may accumulate as approved in the H 2 S Contingency Plan.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC for the ventilation device if it is not explosion-proof. Issue a facility shut-in ( S ) INC if ventilation devices are not situated as approved in the H 2 S Contingency Plan in areas where H 2 S and SO 2 may accumulate.

INSPECTION FORM:

Enter one item checked for each device inspected.

H-145 ARE MOVABLE, MULTIDIRECTIONAL VENTILA TION DEVICES CAPABLE OF DISPERSING

H 2 S OR SO 2 VAPORS AWAY FROM WORKING PER SONNEL PROVIDED IN WORK AREAS? Authority: 490(k)(2)(iii)

Enforcement Action: C

INSPECTION PROCEDURE: Visually inspect work areas to verify that movabl e, multidirectional ventilation devices capable of dispersing H 2 S and SO 2 vapors are provided.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC for the work area if movable, multidirectional ventilation devices capable of dispersing H 2 S and SO 2 vapors are not provided.

INSPECTION FORM: Enter one item checked per facility.

H-146 IF WATER-BASED, WELL-CONTROL FLUIDS ARE USED, AND IF H 2 S IS DETECTED BY AIR SENSORS, HAS THE GARRETT-GAS-TRAIN TEST OR COMPARABLE TEST TECHNIQUES

FOR SOLUBLE SULFIDES BEEN CONDUCTED? Authority: 490(m)(2)

Enforcement Action: W

INSPECTION PROCEDURE: 1. Check Shell's records to verify that the Garrett-Gas-Train test or comparable test for soluble

sulfides has been conducted if H 2 S was detected when using wate r-base well-control fluids.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 101 2. If the concentration detected by air sensors is in excess of 20 ppm, personnel conducting the tests shall don protective-breathing equipment.

Note: The Garrett-Gas-Train test is descr ibed in API RP 13B, Appendix A.16.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if the Garrett-Gas-Train test or co mparable test for soluble sulfides has not

been conducted when H 2 S was detected.

INSPECTION FORM: Enter one item checked per facility.

H-147
ARE SUFFICIENT QUANTITIES OF ADDI TIVES (SCAVENGERS, pH, AND CORROSION CONTROL) MAINTAINED ON THE FACILITY? Authority: 490(m)(4)(i)

Enforcement Action: S 490(m)(4)(ii) 490(m)(4)(iii)

INSPECTION PROCEDURE: Visually inspect the facility to verify that su fficient quantities of additives as approved in the H 2 S Contingency Plan are av ailable for the:

1. Control of H 2 S (scavengers). 2. Control of well-control fluid pH. 3. Control for corrosion of equipment.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if sufficient quantities of additive s are not available to control:

1. H 2 S. 2. Well-control fluid pH. 3. Corrosion of equipment.

INSPECTION FORM: Enter one item checked per facility.

H-148 WHEN

H 2 S IS DETECTED, IS DRILLING SUSPENDED UNTIL SCAVENGER IS CIRCULATED

THROUGHOUT THE SYSTEM? Authority: 490(m)(4)(i)

Enforcement Action: S

INSPECTION PROCEDURE: If present on the facility during the detection of H 2 S, observe to see if drilling is suspended until scavenger is circulated throughout system.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if drilling is not suspended and scavenger is not circulated throughout the system.

INSPECTION FORM: Enter one item checked per facility.

H-149 IS THE pH OF WATER-BASED WELL-CONTROL FLUIDS MAINTAINED AT A MINIMUM OF

10.0?Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 102 Authority: 490(m)(4)(ii)

Enforcement Action: S

INSPECTION PROCEDURE: Check the Shell’s records to verify that the pH of water-based well-control fluids is maintained at a

minimum of 10.0.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if the pH of well-control fluids is not maintained at a minimum of 10.0.

INSPECTION FORM: Enter one item checked per facility.

H-150
ARE WELL-CONTROL FLUIDS CONTAINING H 2 S DEGASSED AT THE OPTIMUM

LOCATION FOR THE PARTICULAR FACILITY AND ARE THE GASSES REMOVED BURNED

IN A CLOSED FLARE SYSTEM? Authority: 490(m)(5)

Enforcement Action: S

INSPECTION PROCEDURE:

1. Review H 2 S Contingency Plan to ascertain optimum location for degasser. 2. Visually inspect the facility to confirm the pr esence of the degasser and t hat it is operative. 3. Visually inspect the flare system to verify that it is a closed system.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if the degasser is not operative or if flare system is not a closed system.
INSPECTION FORM: Enter one item checked for each flare system inspected.

H-151
IS A SAFETY MEETING CONDUCTED FOR ALL PERSONNEL WHO WILL BE ON THE

FACILITY PRIOR TO WELL TESTING? Authority: 490(o)(1)

Enforcement Action: C

INSPECTION PROCEDURE: Check Shell's records to verify th at a safety meeting was held for a ll personnel prior to well testing operations.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC for well testing operations if a safety meeting for all personnel was not conducted prior to co mmencing well testing.

INSPECTION FORM: Enter one item checked per facility.

H-152
ARE ALL GASES PRODUCED DURING TESTING BURNED THROUGH A FLARE SYSTEM WHICH MEETS THE REQUIREMENTS OF 30 CFR 490(o)(3)? Authority: 490(o)(3)

Enforcement Action: S

INSPECTION PROCEDURE:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 103 Visually inspect the well testi ng operation and equipment to veri fy that all gases produced during testing will be routed to the flar e system and burned as prescribed by the requirements of 30 CFR 490(o)(3).

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if the gases produced during well te sting are not routed into the flare system and burned as per the requir ements of 30 CFR 490(o)(3).

INSPECTION FORM: Enter one item checked per facility.

H-153
ARE FLARE LINE OUTLETS LOCATED ON THE DOWNWIND SIDE AND AS FAR FROM THE

FACILITY AS IS FEASIBLE? Authority: 490(q)(6)

Enforcement Action: S

INSPECTION PROCEDURE: Visually inspect the facility to verify t hat the flare line outl ets are located:
1. On the downwind si de of the facility. 2. As far from the facility as is feasible.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if the flare line outlets are not located as required.

INSPECTION FORM: Enter one item checked per facility.

H-154
IS THE FLARE OUTLET EQUIPPED WITH AN AUTOMATIC IGNITION SYSTEM INCLUDING

A PILOT-LIGHT GAS SOURCE OR AN EQUIVALENT SYSTEM? Authority: 490(q)(6)

Enforcement Action: S

INSPECTION PROCEDURE: Visually inspect the flare system to verify that it is equipped with an aut omatic ignition system including a pilot-light gas s ource or an equivalent system.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if the flare system is not equi pped with an automatic ignition system including a pilot-light gas s ource or an equivalent system.

INSPECTION FORM: Enter one item checked per facility.

H-155
IS AN ALTERNATE METHOD AVAI LABLE FOR IGNITING THE FLARE? Authority: 490(q)(6)

Enforcement Action: W

INSPECTION PROCEDURE: Visually inspect the flare system to verify that an alternate method of ignition is provided.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if an alternate method of igniting the flare is not provided.

INSPECTION FORM: Enter one item checked per facility.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 104 H-156
ARE ALL VENTS USED FOR H 2 S PRODUCTION PROCESS EQUIPMENT, TANKS, RELIEF VALVES, BURST PLATES, AN D SIMILAR DEVICES PIPED TO THE FLARE SYSTEM? Authority: 490(q)(6)

Enforcement Action: C/S

INSPECTION PROCEDURE: Visually inspect the facility to verify that all vents are piped to the flare system used for H 2 S for: 1. Production process equipment.

2. Tanks.

3. Relief valves. 4. Burst plates.
5. Similar devices.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if certain components are not vented properly. Issue a facility shut-in ( S ) INC if all components on the fa cility are not vented properly.

INSPECTION FORM: Enter one item checked per component inspected.

H-157
IS GAS CONTAINING H 2 S NOT USED FOR INSTRUMENT GAS, AND IF H 2 S IS BEING USED AS FUEL GAS, DOES THE SHELL HAVE APPR OVAL FROM THE DISTRICT SUPERVISOR? Authority: 490(q)(9)

Enforcement Action: S

INSPECTION PROCEDURE: 1. Check Shell's records and inspect all instru ments for any indication that gas containing H 2 S may be being used for instruments.

2. Check Shell's records and all combustion devic es for indications t hat gas containing H 2 S may be used for fuel. The District Supervisor ma y approve the use of gas containing H 2 S for fuel. If no approval has been given and indications are present, Shell must prove that gas used for fuel does

not contain H 2 S.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if gas containing H 2 S is used for instruments or if gas containing H 2 S is used for fuel without the prior appr oval of the District Supervisor.

INSPECTION FORM: Enter one item checked for each facility.

H-158
HAS THE DISTRICT SUPERVISOR BEEN NOTIFIED IF PRODUC ED WATER IS DISPOSED OF

BY MEANS OTHER THAN SUBSURFACE INJECTION? Authority: 490(q)(12)

Enforcement Action: S

INSPECTION PROCEDURE: Inspect the production process system to verify that produced water to be disposed of by means other than subsurface injecti on is treated for removal of H 2 S.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if the produced water to be disposed of by means other than subsurface injection is not treated for removal of H 2 S and does not have approval by the District Supervisor.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 105 INSPECTION FORM: Enter one item checked per facility.

H-159

ARE H 2 S LEVELS CONTINUOUSLY MONITO RED IN THE WORK AREAS DURING DRILLING, WELL-COMPLETION, AND WELL-WORKOVER OPERATIONS? Authority: 490(j)(4)(i)

Enforcement Action: W/S 490(j)(4)(ii) 490(j)(4)(iii) 490(j)(4)(iv) 490(j)(4)(v)

INSPECTION PROCEDURE: 1. Check Shell's records to verify that H 2 S levels were monitored in the work area when: A. Pulling a wet string of drill pipe; B. Pulling a workover string; C. Circulating bottoms-up a fter a drilling break; D. Cementing; E. Logging; and F. Circulating to condition mud or other well-control fluids. 2. If present during such operat ions, verify that the required monitoring is being conducted.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that monitoring was not conducted during such operations. Issue a facility shut-in ( S ) INC if such monitoring is not being conducted when present during such operations.
INSPECTION FORM: Enter one item checked per facility.

H-160 WHEN CONDUCTING CORING OPERATIONS, IS PROTECTIVE BREATHING EQUIPMENT

WORN BY ALL PERSONNEL IN THE WORK AREA AT LEAST 10 STANDS IN ADVANCE OF

RETRIEVING THE CORE BARREL? Authority: 490(q)(1)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Check Shell's records to verify that protecti ve breathing equipment was worn by personnel in the

work area at least 10 stands in advance of retrie ving the core barrel during conventional coring operations. 2. If present during such operations , verify that protective breathi ng equipment is worn by personnel in the work area at least 10 stands in advance of retrieving the core barrel during conventional coring operations.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that protecti ve breathing equipment was not worn by personnel in the work area at least 10 stands in advance of retrieving the core barrel during conventional coring operations.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 106 Issue a facility shut-in ( S ) INC if protective breathing equipment is not worn by personnel in the work area at least 10 stands in advance of retrieving the core barrel during conventional coring operations, if present dur ing such operations.

INSPECTION FORMS: Enter one item checked per facility.

H-161
ARE ALL CORES TO BE TRANSPORTED SEA LED AND MARKED FOR THE PRESENCE OF

H 2 S? Authority: 490(q)(1)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Check Shell's records to verify that all core s to be transported were sealed and marked for the presence of H 2 S. 2. If present on the facility, ins pect all cores to verify that they have been sealed and marked for the presence of H 2 S.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that cores we re not sealed and marked for the presence

of H 2 S. Issue a facility shut-in ( S ) INC if cores are not sealed a nd marked for the presence of H 2 S if present on the facility during inspection.

INSPECTION FORM: Enter one item checked per facility.

H-162
IS WELL-CONTROL FLUID IN USE FOR LOGGING OPERATIONS CONDITIONED AND

TREATED TO MINIMIZE THE EFFECT OF H 2 S ON THE LOGGING EQUIPMENT? Authority: 490(q)(2)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Inspect Shell's records to verify that well-cont rol fluids in use during logging operations were

conditioned and treated to mi nimize the effect of H 2 S on the logging equipment. 2. If present during logging operations, observe well-control fluid handling operations and check records to verify that the well-c ontrol fluids have been conditioned and treated to minimize the effect

of H 2 S on the logging equipment.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that the we ll-control fluids in use during logging operations were not condi tioned and treated to minimi ze the effect of H 2 S on the logging equipment. Issue a facility shut-in ( S ) INC if present during l ogging operations and the well-control fluids have

not been conditioned and treated to minimize the effect of H 2 S on the logging equipment.

INSPECTION FORM: Enter one item checked per facility.

H-163 DURING STRIPPING OPERATIONS, ARE DI SPLACED WELL-CONTROL FLUID RETURNS

MONITORED BY PERSONNEL? Authority: 490(q)(3)

Enforcement Action: W/SHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 107 INSPECTION PROCEDURE: 1. Check Shell's records to verify that well-contro l fluid returns were monitored by personnel during stripping operations. 2. If present during stripping op erations, observe well-control fluid returns for the presence of monitoring personnel.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that well-cont rol fluid returns were not monitored by personnel during stripping operations. Issue a facility shut-in ( S ) INC if present during st ripping operations and well-con trol fluid returns are not monitored by personnel.

INSPECTION FORM: Enter one item checked per facility.

H-164 DURING STRIPPING OPERATIONS, IS PROT ECTIVE BREATHING EQUIPMENT WORN BY

PERSONNEL IN THE WORK AREA WHEN TH E ATMOSPHERIC CONCENTRATION OF H 2 S

REACHES OR EXCEEDS 20 PPM OR IF THE WELL IS UNDER PRESSURE? Authority: 490(q)(3)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Check Shell's records to verify that protecti ve breathing equipment was worn by personnel in the work area during stripping operations when the concentration of H 2 S reached or exceeded 20 ppm, or if the well was under pressure. 2. If present during stripping oper ations and the concentration of H 2 S equals or exceeds 20 ppm, or if the well is under pressure, observe the work area to verify that personnel are wearing protective breathing equipment.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that personnel did not wear protective breathing equipment during stripping operations when the concentration of H 2 S reached or exceeded 20 ppm, or if the well was under pressure. Issue a facility shut-in ( S ) INC if present during stripping operations and prot ective breathing equipment is not worn by personnel in the work area if th e concentration of H 2 S reaches or exceeds 20 ppm, or if the well is under pressure.

INSPECTION FORM: Enter one item checked per facility.

H-165
IS PROTECTIVE BREATHING EQUIPMENT WORN BY PERSONNEL IN THE WORK AREA

DURING BOTTOMS-UP WHEN CIRCULATING OU T A KICK AND DURI NG EXTENDED KILL
OPERATIONS? Authority: 490(q)(4)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Check Shell's records to verify that protecti ve breathing equipment was worn by personnel in the work area during bottoms-up when circulating out a kick and during extended kill operations. 2. If present during bottoms-up when circulati ng out a kick and during extended kill operations,

observe theHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 108 work area to verify that personnel are w earing protective br eathing equipment.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that personnel did not wear protective breathing equipment during bottoms-up when circulating out a kick and during extended kill operations. Issue a facility shut-in ( S ) INC for the facility if present during bottoms-up when circulating out a kick and during extended kill oper ations if personnel in the work area are not wearing protective breathing equipment.

INSPECTION FORM: Enter one item checked per facility.

H-166
IS AN EFFECTIVE MEANS OF MONITORING AND CONTROLLING CORROSION CAUSED BY

ACID GASES USED IN BOTH THE DOWNHOLE AND SURFACE PORTIONS OF A

PRODUCTION SYSTEM? Authority: 490(q)(7)

Enforcement Action: S

INSPECTION PROCEDURE: Check Shell's records and observe production system for indications of corrosion monitoring and control equipment. The Shell must prove that su ch means for monitoring and controlling corrosion

exist.

IF NONCOMPLIANCE EXISTS: Issue a facility shut-in ( S ) INC if records and observations indi cate that an effective means of monitoring and controlling corrosion in both the dow nhole and surface porti ons of the production system does not exist.

INSPECTION FORM: Enter one item checked per facility.

H-167
ARE LUBRICATORS WHICH MAY BE E XPOSED TO FLUIDS CONTAINING H 2 S MADE OF

H 2 S-RESISTANT MATERIALS? Authority: 490(q)(8)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Check Shell's records to verify that lubricators exposed to fluids containing H 2 S were made of H 2 S

resistant materials. 2. If present when lubricators ar e installed, visually inspect t he lubricator for make and model and verify with records that they are made of H 2 S resistant material.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if Shell’s records indicate that lubricators exposed to fluids containing H 2 S

were not made of H 2 S resistant material. Issue a facility shut-in ( S ) INC if the lubricators which ma y be exposed to fluids containing H 2 S and in use during the inspection are not made of H 2 S resistant materials.

INSPECTION FORM:

Enter one item checked for each lubricator.

H-168
ARE METALS USED FOR SENSING LINES AND SAFETY-CONTROL DEVICES WHICH ARE

EXPOSED TO H 2 S BEARING FLUIDS CONSTRUCTED OF H 2 S CORROSION RESISTANTHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 109 MATERIALS OR COATED WITH APPROPRIATE MATERIALS SO AS TO RESIST

CORROSION? Authority: 490(q)(10)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Check Shell's records to verify that metals used in sensing lines and safety-control devices which were exposed to H 2 S bearing fluids were constructed with H 2 S corrosion resistant materials or coated with appropriate materials so as to resist corrosion. 2. If present on the facility during operations in a known H 2 S zone, verify that the metals and safetycontrol devices are properly constructed or coated.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if the metals were not properly c onstructed or coated so as to resist H 2 S

corrosion. Issue a facility shut-in ( S ) INC if present on the facility during operations in a known H 2 S bearing zone and the metals and safety-control devices are not properly constr ucted or coated.

INSPECTION FORM: Enter one item checked per facility. .

H-169
ARE ALL SEALS WHICH MAY BE EXPOSED TO FLUIDS CONTAINING H 2 S MADE OF H 2 SRESISTANT MATERIAL? Authority: 490(q)(11)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Inspect records to verify that all seals, wh ich were in service while operating in a known H 2 S zone and which may have been exposed to fluids containing H 2 S, were made of H 2 S-resistant material. 2. If present while operations are conducted in a known H 2 S zone, verify that all seals, which may be exposed to fluids containing H 2 S, are made of H 2 S-resistant material by visual observation and

records checks.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate that seals, which may have been exposed to fluids containing H 2 S, were not made of H 2 S-resistant material. Issue a facility shut-in ( S ) INC if seals which may be exposed to fluids containing H 2 S are not

constructed of H 2 S resistant material, if witness ed during operations in a known H 2 S zone.

INSPECTION FORM: Enter one item checked per facility.

H-170
DO TRAINED EMPLOYEES OR CONTRACT ORS TRANSFERRED FROM ANOTHER

FACILITY RECEIVE A SUPPLEMENTAL BRIEFING ON H 2 S EQUIPMENT AND PROCEDURES

BEFORE BEGINNING DUTY? Authority: 490(g)(3)(i)

Enforcement Action: W

INSPECTION PROCEDURE: Verify that all Shell an d contract personnel from other facili ties have received a supplemental briefing on H 2 S equipment and procedures for this facility.

IF NONCOMPLIANCE EXISTS:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 110 Issue a warning ( W ) INC if any Shell or contract personnel have not received a supplemental briefing for this facility.

INSPECTION FORM: Enter one item checked per facility.

H-171
DO VISITORS WHO REMAIN AT THE FACILI TY FOR MORE THAN 24 HOURS RECEIVE THE
TRAINING REQUIRED FOR EMPLOYEES AND CONTRACTORS? Authority: 490(g)(3)(ii)

Enforcement Action: W

INSPECTION PROCEDURE: Verify that all visitors that will be on the facili ty for more than 24 hours have received the same training as required for the Shells and contractors.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if any visitors are on the facilit y more than 24 hours without receiving the same required training as t he Shells and contractors.

INSPECTION FORM: Enter one item checked per facility.

H-172
DO VISITORS WHO WILL DEPART THE F ACILITY WITHIN 24 HOURS RECEIVE A

BRIEFING ON H 2 S PROCEDURES? Authority: 490(g)(3)(iii)

Enforcement Action: W

INSPECTION PROCEDURES: Verify that all visitors departing the facilit y within 24 hours have received a briefing on H 2 S procedures.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records show any visitors departing the facility within 24 hours have not received the required briefing.

INSPECTION FORM: Enter one item checked per facility.

H-173
ARE RECORDS OF ATTENDANCE IN DRI LLS FOR DRILLING, WELL-COMPLETION, AND

WELL-WORKOVER OPERATIONS MAINTAINED AT THE FACILITY UNTIL OPERATIONS

ARE COMPLETED? Authority: 490(h)(2)(i)

Enforcement Action: W

INSPECTION PROCEDURE: Verify that drill attendance record s for drilling, well-completion, an d well-workover operations are maintained on the facility until operations are completed.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records for drills for drilling, well-completion, and well-workover operations are not being maintained at the facility.

INSPECTION FORM: Enter one item checked per facility.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 111 H-174
ARE RECORDS OF ATTENDANCE IN DR ILLS FOR PRODUCTION OPERATIONS

MAINTAINED AT THE FACILITY OR TH E NEAREST FIELD OFFICE FOR 1 YEAR? Authority: 490(h)(2)(ii)

Enforcement Action: W

INSPECTION PROCEDURE: Verify that records of attendance in drills for pr oduction operations are main tained on the facility or the nearest field office for 1 year.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records of attendance in dr ills for production operations are not maintained at the facility or nearest field office for 1 year.

INSPECTION FORM: Enter one item checked per facility.

H-175
ARE PORTABLE OR STRATEGICALLY PLACED FIXED S0 2 DEVICES CAPABLE OF

DETECTING A MINIMUM OF 2 PPM OF SO 2 AVAILABLE OR IN USE AT THE FACILITY? Authority: 490(j)(11)(i)

Enforcement Action: W/S

INSPECTION PROCEDURE: 1. Verify that portable SO 2 devices are available on the facility. 2. Verify that strat egically placed fixed SO 2 devices in use on the facility are capable of detecting a minimum of 2 ppm of SO 2 IF NONCOMPLIANCE EXISTS: 1. Issue a warning ( W ) INC if portable SO 2 devices capable of detecting a minimum of 2 ppm of SO 2 are not available and flaring is not ongoing. 2. Issue a facility shut-in ( S ) INC if strategically placed fixed SO 2 devices are not available on the facility or not capable of detecting 2 ppm of SO 2 during flaring.

INSPECTION FORM:

Enter one item checked for each device inspected.

H-176 ARE PORTABLE OR FIXED SO 2 ELECTRONIC SENSING DEVICES CALIBRATED

EVERY
3 MONTHS? Authority: 490(j)(11)(iv)

Enforcement Action: W/S

INSPECTION PROCEDURE: Verify that portable or fixed SO 2 electronic sensing devices have been calibrated every 3 months.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if records indicate a period was greater than 3 months between calibrations but subsequent calibrations were conducted within the required time period. Issue a facility shut-in ( S ) INC if inspection shows the last ca libration occurred more than 3 months

ago. INSPECTION FORM: Enter one item checked per facility.

H-177
ARE SPECTACLE KITS AVAILABL E FOR RESPIRATORS AS NEEDED?Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 112 Authority: 490(j)(13)(iv)

Enforcement Action: W

INSPECTION PROCEDURE: Inspect all respirators that require spectacle ki ts for specified personnel with vision problems.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC when spectacle kits in respirators are not issued to specified personnel.

INSPECTION FORM: Enter one item checked per respirator inspected.

H-178
ARE COMPRESSORS EXCEEDING 50 HP COVERED BY AT LEAST TWO H 2 S SENSORS

LOCATED WITHIN 10 FEET OF THE COMPRESSOR? Authority: 490(j)(5)(iv)

Enforcement Action: C

INSPECTION PROCEDURE: Verify that at least two H 2 S sensors are located within 10 feet of each compressor that exceeds 50 hp.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if there are not at least two s ensors located within 10 feet of any compressor that exceeds 50 hp.

INSPECTION FORM: Enter one item checked per inspection.

H-179 WHEN DRILLING, ARE FUNCTIONAL TESTS OF H 2 S DETECTORS INITIATED BEFORE THE BIT IS 1,500 FEET (VERTICALLY) ABOVE THE POTENTIAL H 2 S ZONE? Authority: 490(j)(7)(i)

Enforcement Action: W

INSPECTION PROCEDURE: Inspect the driller’s log to verify that functional tests are initia ted before the bit is 1,500 feet (vertically) above the potential H 2 S zone.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if functional tests are not initiat ed before the bit is 1,500 feet (vertically) above any potential H 2 S zone.

INSPECTION FORM: Enter one item checked per inspection.

H-180 WHEN CONDUCTING PRODUCTION OPERATIONS, ARE ALL H 2 S DETECTORS TESTED AT

LEAST EVERY 14 DAYS? Authority: 490(j)(7)(ii)

Enforcement Action: C

INSPECTION PROCEDURE: Verify that all H 2 S detectors are being tested at least every 14 days.

IF NONCOMPLIANCE EXISTS: Issue a component shut-in ( C ) INC if records indicate that any H 2 S detector is not being tested at least every 14 days.

INSPECTION FORM:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 113 Enter one item checked per facility.

H-181
IN AREAS CLASSIFIED AS H 2 S PRESENT , ARE ALL H 2 S DETECTORS TESTED ONCE EVERY

24 HOURS WHEN CONDUCTING DRILLING O PERATIONS, DRILL STEM TESTING, WELL TESTING, WELL COMPLETION OPERAT IONS, OR WORKOVER OPERATIONS? Authority: 490(j)(7)(i)

Enforcement Action: W/S

INSPECTION PROCEDURE: Verify that all H 2 S detectors are being test ed once every 24 hours.

IF NONCOMPLIANCE EXISTS: Issue a warning ( W ) INC if each H 2 S detector is not tested within the 24-hour time period, but subsequent tests were conducted as required. Issue a facility shut-in ( S ) INC if each H 2 S detector is not tested withi n the 24-hour time period and subsequent tests were not conducted.

INSPECTION FORM: Enter one item checked per facility.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 114 SECTION D-3

29 CFR - CHAPTER XVII - PART 1910 THIS DATA CURRENT AS OF THE FEDERAL REGISTER DATED APRIL 25, 2003

§134. Respiratory protection

This section applies to General Industry (part 1910), Shipyards (part 1915), Marine Terminals (part 1917), Longshoring (part 1918), a nd Construction (part 1926).

(a) Permissible practice. (1) In the control of those occupati onal diseases caused by breathing air contaminated with harmful dusts, fogs , fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering c ontrol measures (for example, enc losure or confinement of the operation, general and local ventilation, and substitu tion of less toxic materials). When effective engineering controls are not feasib le, or while they are being instit uted, appropriate respirators shall be used pursuant to this section.

(2) Respirators shall be provided by the em ployer when such equipment is necessary to protect the health of the empl oyee. The employer shall prov ide the respirators which are applicable and suitable for the pur pose intended. The employer shall be responsible for the

establishment and maintenance of a respiratory protection pr ogram which shall include the requirements outlined in paragr aph (c) of this section.

(b) Definitions. The following definitions ar e important terms used in the respiratory protection

standard in this section.

Air-purifying respirator means a respirator with an air-purifyi ng filter, cartridge, or canister that removes specific air contaminants by passing am bient air through the air-purifying element.

Assigned protection factor (APF) [Reserved]

Atmosphere-supplying respirator means a respirator that supplies the respirator us er with breathing air from a source independent of the ambient atmosphere, and in cludes supplied-air respirators (SARs) and self-contained breathi ng apparatus (SCBA) units.

Canister or cartridge means a container with a f ilter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air passed through the container.

Demand respirator means an atmosphere-supplying respirat or that admits breathing air to the facepiece only when a negative pressure is cr eated inside the facepiece by inhalation.

Emergency situation means any occurrence such as, but not limited to, equipment fa ilure, rupture of containers, or failure of control equipment that may or does resu lt in an uncontrolled significant

release of an airborne contaminant.

Employee exposure means exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 115 End-of-service-life indicator (ESLI) means a system that warns the respirator user of the approach of the end of adequate respiratory protection, for example, t hat the sorbent is approaching saturation or is no longer effective.

Escape-only respirator means a respirator intended to be used only for emergency exit.

Filter or air purifying element means a component used in respir ators to remove solid or liquid aerosols from the inspired air.

Filtering facepiece (dust mask) means a negative pressure parti culate respirator with a filter as an integral part of the facepiece or with the entir e facepiece composed of the filtering medium.

Fit factor means a quantitative estimate of the fit of a par ticular respirator to a specific individual, and typically estimates the ratio of the concentration of a substance in ambient air to its concentration inside the respirator when worn.

Fit test means the use of a protocol to qualitatively or quantitatively eval uate the fit of a respirator on an individual. (See also Qualitative fit test QLFT and Quantitative fit test QNFT.)

Helmet means a rigid respiratory inlet covering that also provides head protection against impact and penetration.

High efficiency particulate air (HEPA) filter means a filter that is at least 99.97% efficient in removing monodisperse particles of 0.3 micrometers in diameter. T he equivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters.

Hood means a respiratory inlet covering that co mpletely covers the head and neck and may also cover portions of the shoulders and torso.

Immediately dangerous to life or health (IDLH) means an atmosphere t hat poses an immediate threat to life, would cause irrevers ible adverse health effects, or woul d impair an indivi dual's ability to escape from a dangerous atmosphere.

Interior structural firefighting means the physical activity of fire suppression, rescue or both, inside of buildings or enclosed structures which are involv ed in a fire situation beyond the incipient stage. (See 29 CFR 1910.155)

Loose-fitting facepiece means a respiratory inlet covering that is designed to form a partial seal with

the face.

Maximum use concentration (MUC) [Reserved].

Negative pressure respirator (tight fitting) means a respirator in which the air pressure inside the facepiece is negative during inhalation with res pect to the ambient air pressure outside the respirator.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 116 Oxygen deficient atmosphere means an atmosphere with an oxygen content below 19.5% by

volume.

Physician or other licensed health care professional (PLHCP) means an individual whose legally permitted scope of practice ( i.e., license, registration, or certif ication) allows him or her to independently provide, or be delegated the responsibility to provide, so me or all of the health care services required by paragr aph (e) of this section.

Positive pressure respirator means a respirator in which the pr essure inside the respiratory inlet covering exceeds the ambient air pr essure outside the respirator.

Powered air-purifying respirator (PAPR) means an air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering.

Pressure demand respirator means a positive pressure atmosphere- supplying respirator that admits breathing air to the facepiece when the positiv e pressure is reduced inside the facepiece by

inhalation.

Qualitative fit test (QLFT) means a pass/fail fit test to assess th e adequacy of respirator fit that relies on the individual's response to the test agent.

Quantitative fit test (QNFT) means an assessment of the adequacy of respirator fit by numerically measuring the amount of l eakage into the respirator.

Respiratory inlet covering means that portion of a respirator that forms the protective barrier between the user's respiratory trac t and an air-purifying device or br eathing air source, or both. It may be a facepiece, helmet, hood, suit, or a mouthpiece respirat or with nose clamp.

Self-contained breathi ng apparatus (SCBA) means an atmosphere-supplyi ng respirator for which the breathing air source is designed to be carried by the user.

Service life means the period of time that a respirator , filter or sorbent, or other respiratory equipment provides adequate pr otection to the wearer.

Supplied-air respirator ( SAR) or airline respirator means an atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user.

This section means this respiratory protection standard.

Tight-fitting facepiece means a respiratory inlet covering that forms a complete seal with the face.

User seal check means an action conducted by the respirator user to determine if the respirator is properly seated to the face.

(c) Respiratory protection program. This paragraph requires the employ er to develop and implement a written respiratory protection pr ogram with required worksite-specif ic procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator. In addition, certai n program elements may be required for voluntary use to preventHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 117 potential hazards associated with the use of the respirator. The Small Entity Compliance Guide

contains criteria for the select ion of a program administrator and a sample program that meets the requirements of this paragraph. Copies of the Small Entity Compliance Guide will be available on or about April 8, 1998 from the Occupational Safety and Health Admini stration's Office of Publications, Room N 3101, 200 Constitution Avenue, NW , Washington, DC, 20210 (202-219-4667).

(1) In any workplace where resp irators are necessary to protec t the health of the employee or whenever respirators are r equired by the employer, the em ployer shall establish and implement a written respiratory protection program with wor ksite-specific procedures. The program shall be updated as necessary to reflec t those changes in workplace conditions that affect respirator use. The em ployer shall include in the progr am the following provisions of this section, as applicable:

(i) Procedures for selecting resp irators for use in the workplace;

(ii) Medical evaluations of empl oyees required to use respirators;

(iii) Fit testing procedures for tight-fitting respirators;

(iv) Procedures for proper use of respir ators in routine and reasonably foreseeable emergency situations;

(v) Procedures and schedules for cleaning, disinf ecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators;

(vi) Procedures to ensure adequate air qua lity, quantity, and flow of breathing air for atmosphere-supplying respirators;

(vii) Training of employees in the respir atory hazards to which they are potentially exposed during routine and emergency situations;

(viii) Training of employees in the proper use of respirators, including putting on and removing them, any limitations on t heir use, and their maintenance; and

(ix) Procedures for regularly evalua ting the effectiveness of the program.

(2) Where respirator use is not required:

(i) An employer may provide respirator s at the request of employees or permit employees to use their own respirators, if th e employer determines t hat such respirator

use will not in itself create a hazard. If the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix D to this section ("Information for Employees Using Respirators When Not Requir ed Under the Standard"); and

(ii) In addition, the employer must estab lish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medi cally able to use that respirat or, and that the respirator isHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 118 cleaned, stored, and maintained so that its use does not present a health hazard to the user. Exception: Employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filteri ng facepieces (dust masks).

(3) The employer shall designate a program adm inistrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness.

(4) The employer shall provide respirators, tr aining, and medical evaluations at no cost to the employee.

(d) Selection of respirators. This paragraph requires the employer to evaluate respiratory hazard(s) in the workplace, identify relevant workplace and user factors, and base re spirator selection on these factors. The paragraph also specifies appropriately protective respirators for use in IDLH atmospheres, and limits the selection and use of air-purifying respirators.

(1) General requirements. (i) The employer shall select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed and workplace and user factors that affect respirator performance and reliability.

(ii) The employer shall select a NIOSH-ce rtified respirator. The respirator shall be used in compliance with the condi tions of its certification.

(iii) The employer shall identify and evaluate the respirator y hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contam inant's chemical state and physical form. Where the em ployer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.

(iv) The employer shall select respirat ors from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user.

(2) Respirators for IDLH atmospheres. (i) The employer shall provide the following respirators for employee use in IDLH atmospheres:

(A) A full facepiece pressure demand SC BA certified by NIOSH for a minimum service life of thirty minutes, or

(B) A combination full facepiece pressu re demand supplied-air respirator (SAR) with auxiliary self-contained air supply.

(ii) Respirators provided only for escape from IDLH atmospheres shall be NIOSHcertified for escape from the atmo sphere in which they will be used.

(iii) All oxygen-deficient atmospheres s hall be considered IDLH. Exception: If the employer demonstrates that, under a ll foreseeable conditions, the oxygenHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 119 concentration can be maintained within the ranges specified in Table II of this section (i.e., for the altitudes set out in the tabl e), then any atmosphere- supplying respirator may be used.

(3) Respirators for atmospher es that are not IDLH. (i) The employer shall provide a respirator that is adequate to protect the heal th of the employee and ensure compliance with all other OSHA statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations.

(A) Assigned Protection Factors (APFs) [Reserved]

(B) Maximum Use Concentration (MUC) [Reserved]

(ii) The respirator selected shall be appr opriate for the chemical state and physical

form of the contaminant.

(iii) For protection against gases and v apors, the employer shall provide:

(A) An atmosphere-supplying respirator, or

(B) An air-purifying respirator, provided that:

( 1 ) The respirator is equipped wit h an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant; or

( 2 ) If there is no ESLI appropriate for conditions in the employer's workplace, the employer implements a change schedule for canisters and cartridges that is based on object ive information or data that will ensure that canisters and cartridges are changed before the end of their service life. The employer shall descr ibe in the respirator program the information and data relied upon and the basis for the canister and cartridge change schedule and the basis for reliance on the data.

(iv) For protection against particula tes, the employer shall provide:

(A) An atmosphere-supplying respirator; or

(B) An air-purifying respirator equipped with a filter certified by NIOSH under 30 CFR part 11 as a high efficiency particulate air (HEPA) filter, or an air-purifying respirator equipped with a filter certified for part iculates by NIOSH under 42 CFR part 84; or

(C) For contaminants consisting prim arily of particles with mass median aerodynamic diameters (MMAD) of at least 2 microm eters, an air-purifying respirator equipped with any filter certified for particulates by NIOSH.

Table I_Assigned Protection Factors [Reserved]Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 120 Table II

------------------------------------------------------------ ------------ Oxygen deficient Atmospheres (% O 2 ) for Altitude (ft.) which the employer may rely on atmosphere-supplying respirators

------------------------------------------------------------ ------------

Less than 3,001..............

................ .............. 16.0-19.5

3,001-4,000................

.................. .............. 16.4-19.5

4,001-5,000................

.................. .............. 17.1-19.5

5,001-6,000................

.................. .............. 17.8-19.5

6,001-7,000................

.................. .............. 18.5-19.5

7,001-8,000 1

.................. ............... ............ 19.3-19.5.

------------------------------------------------------------ ------------

1 Above 8,000 feet the ex ception does not apply. Oxygen-enriched breathing air must be supplied above 14,000 feet.

(e) Medical evaluation. Using a respirator may place a ph ysiological burden on employees that varies with the type of respirator worn, the job and workplace conditions in which the respirator is used, and the medical status of the employee. A ccordingly, this paragraph specifies the minimum requirements for medical evaluation that employer s must implement to determine the employee's ability to use a respirator.

(1) General. The employer shall provide a medica l evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.

(2) Medical evaluation procedures. (i) The employer shall id entify a physician or other licensed health care professional (PLHCP) to perform medical evaluati ons using a medical questionnaire or an initial medi cal examination that obtains the same information as the medical questionnaire.

(ii) The medical evaluation shall obtain the information requested by the questionnaire in Sections 1 and 2, Part A of Appendix C of this section.

(3) Follow-up medical examination. (i) The employer shall ensure that a follow-up medical examination is provided for an employee wh o gives a positive response to any questionHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 121 among questions 1 through 8 in Section 2, Part A of Appendix C or whose initial medical

examination demonstrates the need for a follow-up medica l examination.

(ii) The follow-up medical ex amination shall include any m edical tests, consultations, or diagnostic procedures t hat the PLHCP deems nece ssary to make a final

determination.

(4) Administration of the medical questionnaire and examinations. (i) The medical questionnaire and examinations shall be admini stered confidentially dur ing the employee's normal working hours or at a time and place convenient to the employee. The medical questionnaire shall be administered in a manner t hat ensures that the employee understands

its content.

(ii) The employer shall provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP.

(5) Supplemental information for the PLHCP. (i) The following information must be provided

to the PLHCP before the PLHCP makes a re commendation concerning an employee's ability to use a respirator:

(A) The type and weight of the respir ator to be used by the employee;

(B) The duration and frequency of respirat or use (including use for rescue and escape);

(C) The expected physical work effort;

(D) Additional protective cl othing and equipment to be worn; and

(E) Temperature and humidity extr emes that may be encountered.

(ii) Any supplemental information provi ded previously to the PLHCP regarding an employee need not be provided fo r a subsequent medical evaluation if the information

and the PLHCP remain the same.

(iii) The employer shall provide the PLHC P with a copy of the written respiratory protection program and a copy of this section.

Note to paragraph

(e)(5)(iii): When the employer replaces a PLHCP, the employer must ensure that the new PLHCP obtains this information, either by providing t he documents directly to the PLHCP or having the

documents transferred from the former PLHCP to the new PLHCP. However, OSHA does not expect employers to have employees medically reevaluated solely because a new PLHCP has been

selected.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 122 (6) Medical determination. In determining the employee's ability to use a respirator, the employer

shall:

(i) Obtain a written recommendation regarding the employee's ability to use the respirator
from the PLHCP. The recomme ndation shall provide only the following information:

(A) Any limitations on respirator use relat ed to the medical condit ion of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the empl oyee is medically able to use the respirator;

(B) The need, if any, for follo w-up medical evaluations; and

(C) A statement that the PLHCP has pr ovided the employee with a copy of the

PLHCP's written recommendation.

(ii) If the respirat or is a negative pressure respirat or and the PLHCP finds a medical condition that may place the employee's health at increased risk if the respirator is used, the employer shall provide a PAPR if the PLHCP's medical evaluation finds that the employee can use such a respirator; if a subsequent m edical evaluation finds that the employee is medically able to use a negative pressure respir ator, then the employer is no longer required to provide a PAPR.

(7) Additional medical evaluations. At a minimum, the employer s hall provide additional medical evaluations that comply with the requirements of this section if:

(i) An employee reports medical signs or sym ptoms that are relat ed to ability to use a respirator;

(ii) A PLHCP, supervisor, or t he respirator program administra tor informs the employer that an employee needs to be reevaluated;

(iii) Information from the re spiratory protection program, in cluding observations made during fit testing and program evaluation, indica tes a need for employee reevaluation; or

(iv) A change occurs in workplace conditions (e .g., physical work effort , protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

(f) Fit testing. This paragraph requires that, before an employee may be required to use any respirator with a negative or positive pressure tight-fitting facepi ece, the employee must be fit tested with the same make, model, style, and size of resp irator that will be used. This paragraph specifies the kinds of fit tests allowed, the procedures for conducting them, and how the results of the fit tests

must be used.

(1) The employer shall ensure that employees using a tight-fitting facepiece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) as stated in this paragraph.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 123 (2) The employer shall ensure that an employee us ing a tight-fitting facepiece respirator is fit tested prior to initial use of t he respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.

(3) The employer shall conduct an additional fi t test whenever the employee reports, or the employer, PLHCP, supervisor, or program administrator make s visual observations of, changes in the employee's physical condition that could affect re spirator fit. Such conditions include, but are not limited to, facial scarri ng, dental changes, cosmetic surgery, or an obvious change in body weight.

(4) If after pa ssing a QLFT or QNFT, the employee subsequently notifie s the employer, program administrator, supervisor, or PLHCP that the fi t of the respirator is unacceptable, the employee shall be given a reasonable opportunity to select a different respirator facepiece

and to be retested.

(5) The fit test shall be administered usi ng an OSHA-accepted QLFT or QNFT protocol. The OSHA-accepted QLFT and QNFT protocols and proc edures are contained in Appendix A of

this section.

(6) QLFT may only be used to fit test negative pr essure air-purifying re spirators that must

achieve a fit factor of 100 or less.

(7) If the fit factor, as det ermined through an OSHA-accepted QN FT protocol, is equal to or greater than 100 for tight-fitting half facepieces, or equal to or greater than 500 for tight-fitting full facepieces, the QNFT has b een passed with that respirator.

(8) Fit testing of tight-fitting atmosphere-s upplying respirators and tight-fitting powered airpurifying respirators shall be accomplished by performing quantitative or qualitative fit testing in the negative pressure mode, regardless of the mode of operation ( negative or positive pressure) that is used for respiratory protection.

(i) Qualitative fit testing of these respirators shall be accomplished by temporarily converting the respirator user's actual fa cepiece into a negative pressure respirator with appropriate filters, or by using an i dentical negative pre ssure air-purifying respirator facepiece with the same sealing surfaces as a surrogate for the atmosphere-supplying or powered air- purifying respirator facepiece.

(ii) Quantitative fit testing of these resp irators shall be accomplished by modifying the facepiece to allow sampling inside the fac epiece in the breathing zone of the user, midway between the nose and mouth. This requirement shall be accomplished by installing a permanent sampling probe onto a surrogate facepiece, or by using a sampling adapter designed to temporarily prov ide a means of sampling air from inside the facepiece.

(iii) Any modifications to the respirator facepiece for fit testing shall be completely removed, and the facepiece restored to NIOSH-approved configur ation, before that facepiece can be used in the workplace.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 124 (g) Use of respirators. This paragraph requires empl oyers to establish and implement procedures for the proper use of respirat ors. These requirements include prohibi ting conditions that may result in facepiece seal leakage, preventing employees from removing respirators in hazardous environments, taking actions to ensure continued effe ctive respirator operation throughout the work shift, and establishing procedures for the use of respirators in IDLH atmospheres or in interior structural firefighting situations.

(1) Facepiece seal protection. (i) The employer shall not pe rmit respirators with tight-fitting facepieces to be worn by employees who have:

(A) Facial hair that comes between the s ealing surface of the facepiece and the

face or that interferes with valve function; or

(B) Any condition that interferes with the face-to-facepiece seal or valve

function.

(ii) If an employee wears corrective glasse s or goggles or other personal protective equipment, the employer shall ensure that such equipment is worn in a manner that

does not interfere with the seal of the facepiece to the face of the user.

(iii) For all tight-fitting resp irators, the employer shall en sure that employees perform a user seal check each time they put on the respirator using the procedures in Appendix B-1 or procedures recommended by the respir ator manufacturer that the employer

demonstrates are as effective as thos e in Appendix B-1 of this section.

(2) Continuing respirator effectiveness. (i) Appropriate surveillance shall be maintained of work area conditions and degree of employee expo sure or stress. When there is a change in work area conditions or degree of employee exposur e or stress that ma y affect respirator effectiveness, the employer shall reevaluate t he continued effectiveness of the respirator.

(ii) The employer shall ensure that em ployees leave the respirator use area:

(A) To wash their faces and respirator facepieces as necessary to prevent eye or skin irritation associated with respirator use; or

(B) If they detect vapor or gas break through, changes in breathing resistance, or leakage of the facepiece; or

(C) To replace the respir ator or the filter, cartri dge, or canister elements.

(iii) If the employee detects vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece, the employer must replace or repair the respirator before allowing the empl oyee to return to the work area.

(3) Procedures for IDLH atmospheres. For all IDLH atmospheres, the employer shall

ensure that:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 125 (i) One employee or, when needed, more than one employee is located outside the IDLH atmosphere;

(ii) Visual, voice, or signal line communi cation is maintained between the employee(s) in the IDLH atmosphere and the employee(s) located outside the IDLH atmosphere;

(iii) The employee(s) located outside t he IDLH atmosphere are trained and equipped to provide effective emergency rescue;

(iv) The employer or desig nee is notified before the em ployee(s) located outside the IDLH atmosphere enter the IDLH atmo sphere to provide emergency rescue;

(v) The employer or designee authorized to do so by the employer, once notified, provides necessary assistance appropriate to the situation;

(vi) Employee(s) located outside t he IDLH atmospheres are equipped with:

(A) Pressure demand or other positive pressure SCBAs, or a pressure demand or other positive pressure supplied-air re spirator with auxiliary SCBA; and either

(B) Appropriate retrieval equipment fo r removing the employee(s) who enter(s) these hazardous atmospheres where retr ieval equipment would contribute to the rescue of the employee( s) and would not increase the overall risk resulting from entry; or

(C) Equivalent means fo r rescue where retrieval equ ipment is not required under paragraph (g)(3)(vi)(B).

(4) Procedures for interior structural firefighting. In addition to the requirements set forth under paragraph (g)(3), in interior structural fires, the employer shall ensure that:

(i) At least two employees enter the IDLH atmosphere and remain in visual or voice contact with one another at all times;

(ii) At least two employees are lo cated outside the IDLH atmosphere; and

(iii) All employees engaged in interior structural firefighting use SCBAs.

Note 1 to paragraph

(g): One of the two individua ls located outside the IDLH atmosphere may be assigned to an additional role, such as incident commander in charge of the emergency or safety officer, so long as this individual is able to perform assistance or rescue activities without jeopardizing the safety or health of any firefighter working at the incident.

Note 2 to paragraphHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 126 (g): Nothing in this section is meant to prec lude firefighters from performing emergency rescue

activities before an entire team has assembled.

(h) Maintenance and care of respirators. This paragraph requires the em ployer to provide for the cleaning and disinfecting, stor age, inspection, and repair of re spirators used by employees.

(1) Cleaning and disinfecting. The employer shall provi de each respirator user with a respirator that is clean, sani tary, and in good working order. The employer shall ensure that respirators are cleaned and disinfec ted using the procedures in Appendix B-2 of this section, or procedures recommended by the respirator m anufacturer, provided that such procedures are of equivalent effectiveness. The respirat ors shall be cleaned and disinfected at the following intervals:

(i) Respirators issued for the exclusiv e use of an employee shall be cleaned and disinfected as often as necessary to be maintained in a sanitary condition;

(ii) Respirators issued to more than one employee shall be cleaned and disinfected before being worn by different individuals;

(iii) Respirators maintained for emergen cy use shall be cleaned and disinfected after each use; and

(iv) Respirators used in fit testing and tr aining shall be cleaned and disinfected after

each use.

(2) Storage. The employer shall ensure that respirators are stored as follows:

(i) All respirators shall be stored to prot ect them from damage, contamination, dust, sunlight, extreme temperatures, excessiv e moisture, and damaging chemicals, and they shall be packed or stor ed to prevent deformation of t he facepiece and exhalation

valve.

(ii) In addition to the requirements of par agraph (h)(2)(i) of this section, emergency respirators shall be:

(A) Kept accessible to the work area;

(B) Stored in compartments or in covers that are clearly marked as containing emergency respirators; and

(C) Stored in accordance with any applicable manufacturer instructions.

(3) Inspection. (i) The employer shall ensure that respirators are inspected as follows:

(A) All respirators used in routine sit uations shall be inspected before each use and during cleaning;Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 127 (B) All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with the manufacturer's recommendations, and shall be checked fo r proper function before and after each use; and

(C) Emergency escape-only respirators shall be inspected before being carried into the workplace for use.

(ii) The employer shall ensure that resp irator inspections include the following:

(A) A check of respirator function, tightness of connections, and the condition of the various parts incl uding, but not limited to, t he facepiece, head straps, valves, connecting tube, and cartri dges, canisters or filters; and

(B) A check of elastomeric parts for pliability and signs of deterioration.

(iii) In addition to the requirements of paragraphs (h)(3)(i) and (ii) of this section, selfcontained breathing appar atus shall be inspected mont hly. Air and oxygen cylinders shall be maintained in a fully charged stat e and shall be recharged when the pressure

falls to 90% of the manufacturer's recomm ended pressure level. The employer shall determine that the regulator and warning devices function properly.

(iv) For respirators maintained fo r emergency use, the employer shall:

(A) Certify the respirator by doc umenting the date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator; and

(B) Provide this information on a tag or label that is attached to the storage compartment for the respirat or, is kept with the resp irator, or is included in inspection reports stored as paper or elec tronic files. This information shall be maintained until replaced followi ng a subsequent certification.

(4) Repairs. The employer shall ensure that resp irators that fail an inspection or are

otherwise found to be defective are removed from service, and are discarded or repaired or adjusted in accordance wit h the following procedures:

(i) Repairs or adjustments to respirators ar e to be made only by persons appropriately trained to perform such operations and sha ll use only the respirator manufacturer's NIOSH-approved parts desi gned for the respirator;

(ii) Repairs shall be made according to the manufacturer's recommendations and specifications for the type and extent of repairs to be performed; and

(iii) Reducing and admission valves, regulat ors, and alarms shall be adjusted or repaired only by the manufacturer or a technician trained by the manufacturer.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 128 (i) Breathing air quality and use. This paragraph requires the employer to provide employees using atmosphere-supplying respirator s (supplied-air and SCBA) with br eathing gases of high purity.

(1) The employer shall ensure that compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiration accord s with the following specifications:

(i) Compressed and liquid oxygen shall meet the United States Pharmacopoeia requirements for medical or breathing oxygen; and

(ii) Compressed breathing air shall meet at least the requi rements for Grade D breathing air described in ANSI/Com pressed Gas Association Commodity Specification for Air, G-7.1-1989, to include:

(A) Oxygen content (v/v) of 19.5-23.5%;

(B) Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less;

(C) Carbon monoxide (CO) content of 10 ppm or less;

(D) Carbon dioxide content of 1,000 ppm or less; and

(E) Lack of noticeable odor.

(2) The employer shall ensure that compress ed oxygen is not used in atmosphere-supplying respirators that have previ ously used compressed air.

(3) The employer shall ensure that oxygen c oncentrations greater than 23.5% are used only in equipment designed for oxy gen service or distribution.

(4) The employer shall ensure that cylinders us ed to supply breathing air to respirators meet the following requirements:

(i) Cylinders are tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transpor tation (49 CFR part 173 and part 178);

(ii) Cylinders of purchased br eathing air have a certificate of analysis from the supplier that the breathing air m eets the requirements for Grade D breathing air; and

(iii) The moisture content in the cylinder does not exceed a dew point of -50 °F (-45.6 °C) at 1 atmosphere pressure.

(5) The employer shall ensure that compressors used to supply breathing air to respirators

are constructed and situated so as to:

(i) Prevent entry of contaminated air into the air-supply system;Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 129 (ii) Minimize moisture cont ent so that the dew point at 1 atmosphere pressure is 10 degrees F (5.56 °C) below the ambient temperature;

(iii) Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Sorbent beds and filter s shall be maintained and replaced or refurbished periodically following the manufacturer's instructions.

(iv) Have a tag containing the most recent change date and the signature of the person authorized by the employer to perform the change. The tag shall be maintained at the compressor.

(6) For compressors that are not oil-lubric ated, the employer shall ensure that carbon monoxide levels in the breathing air do not exceed 10 ppm.

(7) For oil-lubricated compressors, the employ er shall use a high-temperature or carbon monoxide alarm, or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply shall be monitored at intervals suffici ent to prevent carbon monoxide in the breathing air from exceeding 10 ppm.

(8) The employer shall ensure that breathing ai r couplings are incompat ible with outlets for nonrespirable worksite air or other gas syst ems. No asphyxiating substance shall be introduced into breathing air lines.

(9) The employer shall use breathing gas containers marked in accordance with the NIOSH respirator certificati on standard, 42 CFR part 84.

(j) Identification of filters, cartridges, and canisters. The employer shall ens ure that all filters, cartridges and canisters used in the workplac e are labeled and color coded with the NIOSH approval label and that the label is not removed and remains legible.

(k) Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirat ors. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirat ors in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.

(1) The employer shall ensure that each em ployee can demonstrate knowledge of at least the following:

(i) Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator;

(ii) What the limitat ions and capabilities of the respirator are;

(iii) How to use the respirat or effectively in emergency sit uations, including situations in which the respirator malfunctions;

(iv) How to inspect, put on and remove, us e, and check the seals of the respirator;Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 130 (v) What the procedures are for maintenance and st orage of the respirator;

(vi) How to recognize medical signs and symptoms that may lim it or prevent the effective use of respirators; and

(vii) The general requirements of this section.

(2) The training shall be conducted in a manner that is understandable to the employee.

(3) The employer shall provide the training prior to requiring t he employee to use a respirator in the workplace.

(4) An employer who is able to demonstrat e that a new employee has received training

within the last 12 months that addresses the elements specified in paragraph (k)(1)(i) through (vii) is not required to repeat such training pr ovided that, as required by paragraph (k)(1), the employee can demonstrate knowledge of those el ement(s). Previous training not repeated initially by the employer must be provided no later than 12 m onths from the date of the previous training.

(5) Retraining shall be adm inistered annually, and when the following situations occur:

(i) Changes in the workplace or the type of respirator render previous training obsolete;

(ii) Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained the requi site understanding or skill; or

(iii) Any other situation arises in which retraining appears necessary to ensure safe respirator use.

(6) The basic advisory information on respirators, as presented in Appendix D of this section, shall be provided by the employer in any wri tten or oral format, to employees who wear respirators when such use is not required by this section or by the employer.

(l) Program evaluation. This section requires the employer to conduct evaluations of the workplace to ensure that the written resp iratory protection program is being properly implemented, and to consult employees to ensure that they are using the respirators properly.

(1) The employer shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current wr itten program are being effect ively implemented and that it

continues to be effective.

(2) The employer shall regularly consult empl oyees required to use respirators to assess the employees' views on program effectiveness and to identify any problems. Any problems that are identified during this assessment shall be corrected. Factors to be assessed include, but

are not limited to:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 131 (i) Respirator fit (including the ability to use the respirator without interfering with effective workplace performance);

(ii) Appropriate respirator selection for t he hazards to which the employee is exposed;

(iii) Proper respirator us e under the workplace condition s the employee encounters;

and

(iv) Proper respirator maintenance.

(m) Recordkeeping. This section requires the employer to establish and retain written information regarding medical evaluations, fit te sting, and the respirator program . This information will facilitate employee involvement in the respirator program, a ssist the employer in auditing the adequacy of the program, and provide a record for compliance determinations by OSHA.

(1) Medical evaluation. Records of medical evaluations required by this section must be

retained and made available in accordance with 29 CFR 1910.1020.

(2) Fit testing. (i) The employer shall establish a reco rd of the qualitativ e and quantitative fit tests administered to an employee including:

(A) The name or identification of the employee tested;

(B) Type of fit test performed;

(C) Specific make, model, style, and size of respirator tested;

(D) Date of test; and

(E) The pass/fail results for QLFTs or t he fit factor and strip chart recording or other recording of the test results for QNFTs.

(ii) Fit test records shall be retained for respirator users until the next fit test is

administered.

(3) A written copy of the current respirator program shall be retained by the employer.

(4) Written materials requir ed to be retained under this paragraph shall be made available upon request to affected employees and to the Assistant Secretary or designee for examination and copying.

(n) Dates -- (1) Effective date. This section is effective April 8, 1998. The obligations imposed by this

section commence on the effective date unless ot herwise noted in this paragraph. Compliance with obligations that do not co mmence on the effective date shall occur no later than the applicable startup date.

(2) Compliance dates. All obligations of this section commence on the effective date except

as follows:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 132 (i) The determination that respirator use is required (paragraph (a)) shall be completed no later than September 8, 1998.

(ii) Compliance with provisions of this section for all other provisions shall be completed no later than October 5, 1998.

(3) The provisions of 29 CFR 1910.134 and 29 CFR 1926.103, contained in the 29 CFR parts 1900 to 1910.99 and the 29 CFR part 1926 editions , revised as of July 1, 1997, are in

effect and enforceable until October 5, 1998, or during any admini strative or judicial stay of the provisions of this section.

(4) Existing respiratory protection programs. If, in the 12 month per iod preceding April 8, 1998, the employer has conducted annual respirator training, fit testing, respirator program evaluation, or medical evaluati ons, the employer may use the re sults of those activities to comply with the corresponding provisions of this section, providing that these activities were

conducted in a manner that meets the requirement s of this section.

(o) Appendices. (1) Compliance with Appendix A, Appen dix B-1, Appendix B-2, and Appendix C of this section is mandatory.

(2) Appendix D of this section is non-mandatory and is not intended to create any additional obligations not other wise imposed or to detract fr om any existing obligations.



### APPENDIX A TO §1910.134 -- FIT TE STING PROCEDURES (MANDATORY)

Part I. OSHA-Accepted Fit Test Protocols

A. Fit Testing Procedur es -- General Requirements

The employer shall conduct fit testing using the following procedures. The requirements in this appendix apply to all OSHA-accepted fi t test methods, both QLFT and QNFT.

1. The test subject shall be allowed to pick the mo st acceptable respirator from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user.

2. Prior to the selection process, the test subject shall be shown ho w to put on a respirator, how it should be positioned on the face, how to set strap tension and how to determine an acceptable fit. A mirror shall be available to assist the subject in evaluating the fit and positio ning of the respirator. This instruction may not constitute the subject's fo rmal training on respirator use, because it is only a

review.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 133 3. The test subject shall be informed that he/she is bei ng asked to select the re spirator that provides the most acceptable fit. Each resp irator represents a different size and shape, and if fitted and used properly, will provide adequate protection.

4. The test subject shall be instructed to hold eac h chosen facepiece up to the face and eliminate those that obviously do not give an acceptable fit.

5. The more acceptable facepieces are noted in case the one selected proves unacceptable; the

most comfortable mask is donned and wo rn at least five minutes to assess comfort. Assistance in assessing comfort can be given by di scussing the points in the following item A.6. If the test subject is not familiar with using a particular respirator, the test subject shall be directed to don the mask several times and to adjust the straps each time to become adept at setting proper tension on the straps.

6. Assessment of comfort shall include a review of the following points with the test subject and allowing the test subject adequate time to determine the comfort of the respirator:

(a) Position of the mask on the nose

(b) Room for eye protection

(c) Room to talk

(d) Position of mask on face and cheeks

7. The following criteria shall be used to hel p determine the adequacy of the respirator fit:

(a) Chin properly placed;

(b) Adequate strap tensi on, not overly tightened;

(c) Fit across nose bridge;

(d) Respirator of proper size to span distance from nose to chin;

(e) Tendency of respirator to slip;

(f) Self-observation in mirror to ev aluate fit and respirator position.

8. The test subject shall conduct a user seal c heck, either the negative and positive pressure seal checks described in Appendix B-1 of this sect ion or those recommended by the respirator manufacturer which provide equiv alent protection to the procedur es in Appendix B-1. Before conducting the negative and positive pressure checks, the subject shall be told to seat the mask on the face by moving the head from side-to-side and up and down slowly while taking in a few slow deep breaths. Another facepiece shall be selected and rete sted if the test subject fails the user seal

check tests.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 134 9. The test shall not be conduct ed if there is any hair growth between the skin and the facepiece sealing surface, such as stubble beard growth , beard, mustache or si deburns which cross the respirator sealing surface. Any ty pe of apparel which interferes with a satisfactory fit shall be altered

or removed.

10. If a test subject exhibits difficulty in breathi ng during the tests, she or he shall be referred to a physician or other licensed health care professional, as appropriate, to deter mine whether the test subject can wear a respirator wh ile performing her or his duties.

11. If the employee finds the fit of the respirator unacceptable, the test s ubject shall be given the opportunity to select a different respirator and to be retested.

12. Exercise regimen. Prior to the commencement of the fit test, the test subject shall be given a description of the fit test and t he test subject's responsibilities during the test procedure. The description of the process shall in clude a description of the test exer cises that the subject will be performing. The respirator to be tested shall be worn for at least 5 minutes bef ore the start of the fit

test.

13. The fit test shall be perform ed while the test subject is wear ing any applicable safety equipment that may be worn during actual respirator us e which could interfere with respirator fit.

14. Test Exercises. (a) The following test exercise s are to be performed for all fit testing methods prescribed in this appendix, except for the CNP me thod. A separate fit testi ng exercise regimen is contained in the CNP protocol. The test subject sha ll perform exercises, in the test environment, in the following manner:

(1) Normal breathing. In a normal standing positi on, without talking, the subject shall breathe normally.

(2) Deep breathing. In a normal standing posi tion, the subject shall breathe slowly and deeply, taking caution so as not to hyperventilate.

(3) Turning head side to side. Standing in place, the subject s hall slowly turn his/her head

from side to side between the ex treme positions on each side. The head shall be held at each extreme momentarily so the s ubject can inhale at each side.

(4) Moving head up and down. Standing in place, t he subject shall slowly move his/her head up and down. The subject shall be instructed to inhale in the up position (i.e., when looking toward the ceiling).

(5) Talking. The subject shall talk out l oud slowly and loud enough so as to be heard clearly by the test conductor. The subject can read from a prepared text such as the Rainbow Passage, count backward from 100, or recite a memorized poem or song.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 135 Rainbow Passage

When the sunlight strikes rai ndrops in the air, they act lik e a prism and form a rainbow. The rainbow is a division of white light into many beautiful colors. These take the shape of a long round arch, with its path high above, and its tw o ends apparently bey ond the horizon. There is, according to legend, a boiling pot of gold at one end. People look, but no one ever finds it. When a man looks for something beyond reach, hi s friends say he is looking for the pot of gold at the end of the rainbow.

(6) Grimace. The test subjec t shall grimace by smiling or frowning. (This applies only to QNFT testing; it is not performed for QLFT)

(7) Bending over. The test subject shall bend at the waist as if he/she were to touch his/her toes. Jogging in place shall be substituted for th is exercise in those test environments such as shroud type QNFT or QLFT units that do not permit bending over at the waist.

(8) Normal breathing. Same as exercise (1).

(b) Each test exercise shall be performed for one minute except for the grimace exercise which shall be performed for 15 seconds. The test subject sha ll be questioned by the test conductor regarding the comfort of the respir ator upon completion of the protocol. If it has become unacceptable, another model of respirator shall be tri ed. The respirator shall not be adj usted once the fit test exercises begin. Any adjustment voids the tes t, and the fit test must be repeated.

B. Qualitative Fit T est (QLFT) Protocols

1. General

(a) The employer shall ensure that persons administering QLFT are able to prepare test solutions, calibrate equipment and perform te sts properly, recognize invalid tests, and ensure that test equipment is in proper working order.

(b) The employer shall ensure that QLFT equipment is kept clean and well maintained so as to operate within the parameters fo r which it was designed.

2. Isoamyl Acetate Protocol

Note:

This protocol is not appropriate to use for the fit testing of particulate respirators. If used to fit test particulate respirators, the respirator mu st be equipped with an or ganic vapor filter.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 136 (a) Odor Threshold Screening

Odor threshold screening, perform ed without wearing a resp irator, is intended to determine if the

individual tested can detect the odor of isoamyl acetate at low levels.

(1) Three 1 liter glass jars with metal lids are required.

(2) Odor-free water (e.g., distille d or spring water) at approximatel y 25 °C (77 °F) shall be used for

the solutions.

(3) The isoamyl acetate (IAA) (also known at isopent yl acetate) stock solution is prepared by adding 1 ml of pure IAA to 800 ml of odor-free water in a 1 liter jar, closing the lid and shaking for 30 seconds. A new solution shall be prepared at least weekly.

(4) The screening test shall be conducted in a room separate from the room used for actual fit testing. The two rooms shall be well-ventilated to prevent the odor of IAA fr om becoming evident in the general room air where testing takes place.

(5) The odor test solution is prepared in a second jar by placing 0.4 ml of the stock solution into 500 ml of odor-free water using a clean dropper or pi pette. The solution shall be shaken for 30 seconds

and allowed to stand for two to three minutes so that the IAA concentration above the liquid may reach equilibrium. This solution shall be used for only one day.

(6) A test blank shall be prepared in a th ird jar by adding 500 cc of odor-free water.

(7) The odor test and test blank jar lids shall be label ed (e.g., 1 and 2) for jar identification. Labels shall be placed on the lids so that they can be peeled off periodically and switched to maintain the integrity of the test.

(8) The following instruction shall be typed on a card and placed on the table in front of the two test jars (i.e., 1 and 2): "The purpose of this test is to determine if you can smell banana oil at a low concentration. The two bottles in front of you cont ain water. One of these bottles also contains a

small amount of banana oil. Be sure the covers ar e on tight, then shake each bottle for two seconds. Unscrew the lid of each bottle, one at a time, and sniff at the mouth of the bottle. Indicate to the test

conductor which bottle contains banana oil."

(9) The mixtures used in the IAA odor detection test shall be prepared in an area separate from where the test is performed, in order to prevent olfactory fatigue in the subject.

(10) If the test subject is unable to correctly identify the jar cont aining the odor test solution, the IAA qualitative fit test shall not be performed.

(11) If the test subject correctly identifies the jar containing t he odor test solution, the test subject may proceed to respirator selection and fit testing.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 137 (b) Isoamyl Acetate Fit Test

(1) The fit test chamber shall be a clear 55-gall on drum liner suspended in verted over a 2-foot diameter frame so that the top of the chamber is about 6 inches above the test subject's head. If no drum liner is available, a similar chamber shall be constructed using plastic sheeting. The inside top

center of the cham ber shall have a small hook attached.

(2) Each respirator used for the fitting and fit testing shall be equipp ed with organic vapor cartridges or offer protection against organic vapors.

(3) After selecting, donning, and proper ly adjusting a respirator, the test subject shall wear it to the fit testing room. This room shall be separate from the room used for odor threshold screening and respirator selection, and shall be well-ventilated, as by an exh aust fan or lab hood, to prevent general room contamination.

(4) A copy of the test exercise s and any prepared text from which the subject is to read shall be taped to the inside of the test chamber.

(5) Upon entering the test chamber, the test subject shall be given a 6- inch by 5-inch piece of paper towel, or other porous, absorbent, single-ply materi al, folded in half and wetted with 0.75 ml of pure IAA. The test subject shall hang the wet towel on the hook at the t op of the chamber. An IAA test swab or ampule may be substituted for the IAA wetted paper towel provided it has been

demonstrated that the alternat ive IAA source will generate an IAA test atmosphere with a concentration equivalent to that generated by the paper towel method.

(6) Allow two minutes for the IAA test concentration to stabilize before starting the fit test exercises. This would be an appropriate time to talk with the te st subject; to explain t he fit test, the importance of his/her cooperation, and the pur pose for the test exercises; or to demonstrate some of the

exercises.

(7) If at any time during the test , the subject detects the banana-like odor of IAA, the test is failed. The subject shall quickly exit fr om the test chamber and leave t he test area to avoid olfactory fatigue.

(8) If the test is failed, the subject shall return to the select ion room and remove the respirator. The test subject shall repeat the odor sensitivity tes t, select and put on another re spirator, return to the test area and again begin the fit test procedure described in (b) (1) through (7) above. The process continues until a respirator that fits well has been found. Should the odor sens itivity test be failed, the subject shall wait at least 5 minutes before retesting. Odor se nsitivity will usually have returned by this time.

(9) If the subject passes the tes t, the efficiency of the test pr ocedure shall be demonstrated by having the subject break the resp irator face seal and take a br eath before exitin g the chamber.

(10) When the test subject leaves the chamber, t he subject shall remove the saturated towel and return it to the person conducting t he test, so that there is no signifi cant IAA concentration buildup in the chamber during subsequent tests. The used towels shall be kept in a self-sealing plastic bag to keep the test area from being contaminated.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 138 3. Saccharin Solution Aerosol Protocol

The entire screening and testing procedur e shall be explained to the test subject prior to the conduct of the screening test.

(a) Taste threshold screening. The saccharin tast e threshold screening, performed without wearing a respirator, is intended to deter mine whether the individual being tested can detect the taste of

saccharin.

(1) During threshold screening as well as during fi t testing, subjects shall wear an enclosure

about the head and shoulders that is approximately 12 inches in diameter by 14 inches tall with at least the front portion clear and that allows free movements of the head when a respirator is worn. An enclosure substantially similar to the 3M hood assembly, parts # FT 14 and # FT 15 combined, is adequate.

(2) The test enclosure shall have a 3/4-inch (1 .9 cm) hole in front of the test subject's nose

and mouth area to accommodat e the nebulizer nozzle.

(3) The test subject shall don the test enclo sure. Throughout the threshold screening test, the test subject shall breathe through his/her slightly open mouth with tongue extended. The subject is instructed to report wh en he/she detects a sweet taste.

(4) Using a DeVilbiss Model 40 Inhalation M edication Nebulizer or equivalent, the test conductor shall spray the threshold check solution into the enclosure. The nozzle is directed away from the nose and mouth of the person. This nebulizer shall be clearly marked to distinguish it from the fit test solution nebulizer.

(5) The threshold check solution is prepared by dissolving 0.83 gram of sodium saccharin USP in 100 ml of warm water. It can be prepared by putting 1 ml of the fi t test solution (see (b)(5) below) in 100 ml of distilled water.

(6) To produce the aerosol, t he nebulizer bulb is firmly squeezed so that it collapses completely, then released and allowed to fully expand.

(7) Ten squeezes are repeated rapidly and then the test subject is asked whether the

saccharin can be tasted. If the test subject reports tasting the sweet taste during the ten squeezes, the screening test is completed. The ta ste threshold is noted as ten regardless of the number of squeezes actually completed.

(8) If the first response is negative, ten mo re squeezes are repeated rapidly and the test subject is again asked whether t he saccharin is tasted. If the te st subject reports tasting the sweet taste during the second ten squeezes, the screening test is completed. The taste threshold is noted as twenty regardless of th e number of squeezes actually completed.

(9) If the second response is negative, ten more squeezes are repeated rapidly and the test subject is again asked whether t he saccharin is tasted. If the te st subject reports tasting the sweet taste during the third set of ten squeezes, the screening test is completed. The taste threshold is noted as thirty regardless of the number of squeezes actually completed.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 139 (10) The test conductor will take note of the number of squeezes requir ed to solicit a taste

response.

(11) If the saccharin is not tasted after 30 squeezes (step 10), the test subject is unable to taste saccharin and may not perform the saccharin fit test.

Note to paragraph 3.

(a): If the test subjec t eats or drinks something sw eet before the screening test, he/she may be unable to taste the weak saccharin solution.

(12) If a taste response is elic ited, the test subject shall be ask ed to take note of the taste for

reference in the fit test.

(13) Correct use of the nebulizer means that appr oximately 1 ml of liquid is used at a time in the nebulizer body.

(14) The nebulizer shall be thoroughly rinsed in water, shaken dry, and refilled at least each morning and afternoon or at least every four hours.

(b) Saccharin solution aerosol fit test procedure.

(1) The test subject may not eat, drink (exc ept plain water), smoke, or chew gum for 15

minutes before the test.

(2) The fit test uses the same enclosure described in 3. (a) above.

(3) The test subject shall don the enclosure whil e wearing the respirator selected in section I. A. of this appendix. The respir ator shall be properly adjusted and equipped with a particulate filter(s).

(4) A second DeVilbiss Model 40 Inhalation Medi cation Nebulizer or equivalent is used to spray the fit test solution into the enclosure . This nebulizer shall be clearly marked to distinguish it from the scr eening test solution nebulizer.

(5) The fit test solution is prepared by adding 83 grams of s odium saccharin to 100 ml of

warm water.

(6) As before, the test s ubject shall breathe th rough the slightly op en mouth with tongue extended, and report if he/she tastes the sweet taste of saccharin.

(7) The nebulizer is inserted into the hole in the front of the enclosure and an initial

concentration of saccharin fit test solution is sprayed into the enclosure using the same number of squeezes (either 10, 20 or 30 squeezes) based on the number of squeezesHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 140 required to elicit a taste response as noted during the screening test. A minimum of 10 squeezes is required.

(8) After generating the aerosol, the test subjec t shall be instructed to perform the exercises in section I. A. 14. of this appendix.

(9) Every 30 seconds the aerosol concentra tion shall be replenished using one half the original number of squeezes used initially (e.g., 5, 10 or 15).

(10) The test subject shall indi cate to the test conductor if at any time during the fit test the

taste of saccharin is detected. If the test subject does not report tasting the saccharin, the test is passed.

(11) If the taste of sacchar in is detected, the fit is deem ed unsatisfactory and the test is failed. A different respirator shall be tried and the entire test procedure is repeated (taste threshold screening and fit testing).

(12) Since the nebulizer has a tendency to clog dur ing use, the test She ll must make periodic

checks of the nebulizer to ensure that it is not clogged. If clogging is found at the end of the test session, the test is invalid.

4. Bitrex TM (Denatonium Benzoate) Solution Aero sol Qualitative Fit Test Protocol

The Bitrex TM (Denatonium benzoate) solution aerosol QLFT protocol uses the published saccharin test protocol because that protocol is widely accept ed. Bitrex is routinely used as a taste aversion agent in household liquids which ch ildren should not be drinking an d is endorsed by the American Medical Association, the National Safety Council, and the American Association of Poison Control Centers. The entire screening and te sting procedure shall be explained to the test subject prior to the conduct of the screening test.

(a) Taste Threshold Screening.

The Bitrex taste threshold screening, performed without wearing a respirator, is intended to determine whether the individual being te sted can detect the taste of Bitrex.

(1) During threshold screening as well as during fi t testing, subjects shall wear an enclosure

about the head and shoulders that is approximately 12 inches (30. 5 cm) in diameter by 14 inches (35.6 cm) tall. The front portion of the enclosure shall be clear from the respirator and

allow free movement of the head when a respirator is worn. An enclosure substantially similar to the 3M hood assembly, parts # FT 14 and # FT 15 combined, is adequate.

(2) The test enclosure shall have a 3/4 inch (1.9 cm) hole in front of the test subject's nose

and mouth area to accommodat e the nebulizer nozzle.

(3) The test subject shall don the test enclo sure. Throughout the threshold screening test, the test subject shall breathe through his or her slightly open mouth with tongue extended. The subject is instructed to report when he/she detects a bitter taste.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 141 (4) Using a DeVilbiss Model 40 Inhalation M edication Nebulizer or equivalent, the test conductor shall spray the Threshold Check Soluti on into the enclosure. This Nebulizer shall be clearly marked to distinguish it from the fit test solution nebulizer.

(5) The Threshold Check Solution is prepared by adding 13.5 milligrams of Bitrex to 100 ml of 5% salt (NaCl) solu tion in distilled water.

(6) To produce the aerosol, t he nebulizer bulb is firmly squeezed so that the bulb collapses completely, and is then released and allowed to fully expand.

(7) An initial ten squeezes are repeated rapidl y and then the test subject is asked whether

the Bitrex can be tasted. If t he test subject reports tasting the bitter taste during the ten squeezes, the screening test is completed. The ta ste threshold is noted as ten regardless of the number of squeezes actually completed.

(8) If the first response is negative, ten mo re squeezes are repeated rapidly and the test subject is again asked whether the Bitrex is tasted. If the test subject reports tasting the bitter taste during the second ten squeez es, the screening test is comple ted. The taste threshold is noted as twenty regardless of the number of squeezes actually completed.

(9) If the second response is negative, ten more squeezes are repeated rapidly and the test subject is again asked whether the Bitrex is tasted. If the test subject reports tasting the bitter taste during the third set of ten squeezes, the screening test is completed. The taste threshold is noted as thirty regardless of the number of squeezes actually completed.

(10) The test conductor will take note of the number of squeezes requir ed to solicit a taste

response.

(11) If the Bitrex is not ta sted after 30 squeezes (step 10), the test subject is unable to taste Bitrex and may not perfor m the Bitrex fit test.

(12) If a taste response is elic ited, the test subject shall be ask ed to take note of the taste for

reference in the fit test.

(13) Correct use of the nebulizer means that appr oximately 1 ml of liquid is used at a time in the nebulizer body.

(14) The nebulizer shall be thor oughly rinsed in water, shaken to dry, and refilled at least each morning and afternoon or at least every four hours.

(b) Bitrex Solution Aerosol Fit Test Procedure.

(1) The test subject may not eat, drink (exc ept plain water), smoke, or chew gum for 15

minutes before the test.

(2) The fit test uses th e same enclosure as that described in 4. (a) above.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 142 (3) The test subject shall don the enclosure wh ile wearing the respirator selected according

to section I. A. of this a ppendix. The respirator shall be pr operly adjusted and equipped with any type particulate filter(s).

(4) A second DeVilbiss Model 40 Inhalation Medi cation Nebulizer or equivalent is used to spray the fit test solution into the enclosure . This nebulizer shall be clearly marked to distinguish it from the scr eening test solution nebulizer.

(5) The fit test solution is prepared by adding 337.5 mg of Bi trex to 200 ml of a 5% salt (NaCl) solution in warm water.

(6) As before, the test subject shall br eathe through his or her slightly open mouth with tongue extended, and be instructed to report if he/she tastes the bitter taste of Bitrex..

(7) The nebulizer is inserted into the hole in the front of the enclosure and an initial concentration of the fit test solution is spray ed into the enclosure using the same number of squeezes (either 10, 20 or 30 squeezes) based on the number of squeezes required to elicit a taste response as noted during the screening test.

(8) After generating the aerosol, the test subjec t shall be instructed to perform the exercises in section I. A. 14. of this appendix.

(9) Every 30 seconds the aerosol concentra tion shall be replenished using one half the number of squeezes used initia lly (e.g., 5, 10 or 15).

(10) The test subject shall indi cate to the test conductor if at any time during the fit test the

taste of Bitrex is detected. If the test subject does not report tasting the Bitrex, the test is passed.

(11) If the taste of Bitrex is detected, the fit is deemed unsatisfactory and the test is failed. A different respirator shall be tr ied and the entire test procedure is repeated (taste threshold screening and fit testing).

5. Irritant Smoke (Stannic Chloride) Protocol

This qualitative fit test uses a person's response to the irritating chemicals released in the "smoke" produced by a stannic chloride ventilation smoke t ube to detect leakage into the respirator.

(a) General Requirements and Precautions

(1) The respirator to be tested shall be equipped wit h high efficiency particulate air (HEPA) or P100 series filter(s).

(2) Only stannic chloride smoke tubes shall be used for this protocol.

(3) No form of test enclosure or hood for the test subject shall be used.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 143 (4) The smoke can be irritating to the eyes, l ungs, and nasal passages. The test conductor shall take precautions to minimize the test subject's exposure to irrit ant smoke. Sensitivity varies, and certain individuals may respond to a greater degree to irritant sm oke. Care shall be taken when performing the sensitivity screening checks that determine whether the test subject can detect irritant smoke to use only the minimum amount of smoke necessary to elicit a response from the test subject.

(5) The fit test shall be performed in an area wit h adequate ventilation to prevent exposure of the person conducting the fit test or the build-up of irritant smoke in the general atmosphere.

(b) Sensitivity Screening Check

The person to be tested must demons trate his or her ability to detec t a weak concentration of the

irritant smoke.

(1) The test Shell shall break both ends of a vent ilation smoke tube contai ning stannic chloride, and

attach one end of the smoke tube to a low flow air pump set to deliver 200 m illiliters per minute, or an aspirator squeeze bulb. The test Shell shall co ver the other end of the smoke tube with a short piece of tubing to prevent potential inju ry from the jagged end of the smoke tube.

(2) The test Shell shall advise the test subject t hat the smoke can be irritating to the eyes, lungs, and nasal passages and instruct the subject to keep his/her eyes clos ed while the test is performed.

(3) The test subject shall be allowed to smell a w eak concentration of the irritant smoke before the respirator is donned to become familiar with its irri tating properties and to determine if he/she can detect the irritating properties of the smoke. The test Shell shall ca refully direct a small amount of

the irritant smoke in the test subject's direction to deter mine that he/she can detect it.

(c) Irritant Smoke Fit Test Procedure

(1) The person being fit tested shall don the respir ator without assistance, and perform the required user seal check(s).

(2) The test subject shall be instru cted to keep his/her eyes closed.

(3) The test Shell shall direct t he stream of irritant smoke from the smoke tube toward the faceseal area of the test subject, using t he low flow pump or the squeeze bulb . The test Shell shall begin at least 12 inches from the facepiece and move the smoke stream around the whole perimeter of the mask. The Shell shall gradually ma ke two more passes around the perim eter of the mask, moving to

within six inches of the respirator.

(4) If the person being tested has not had an involuntary response and/or detected the irritant smoke, proceed with the test exercises.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 144 (5) The exercises identified in se ction I.A. 14. of this appendix shall be performed by the test subject while the respirator seal is bei ng continually challenged by the sm oke, directed around the perimeter of the respirator at a distance of six inches.

(6) If the person being fit tested repor ts detecting the irritant smoke at any time, the test is failed. The person being retested must repeat the entire sensitivity check and fit test procedure.

(7) Each test subject passing the irritant smoke te st without evidence of a response (involuntary cough, irritation) shall be given a second sensitiv ity screening check, with t he smoke from the same smoke tube used during the fit te st, once the respirator has been removed, to determine whether
he/she still reacts to the smoke. Failure to evoke a response shall void the fit test.

(8) If a response is produced during this second s ensitivity check, then t he fit test is passed.

C. Quantitative Fit Test (QNFT) Protocols

The following quantitative fit testing procedu res have been demonstrat ed to be acceptable: Quantitative fit testing using a no n-hazardous test aerosol (such as corn oil, polyethylene glycol 400 [PEG 400], di-2-ethyl hexyl sebaca te [DEHS], or sodium chloride) generated in a test chamber, and employing instrumentation to quantif y the fit of the respir ator; Quantitative fit testing using ambient aerosol as the test agent and appropriate instrum entation (condensation nuclei counter) to quantify the respirator fit; Quantitati ve fit testing using controlled negative pressure and appropriate

instrumentation to measure the volumetric leak rate of a facepiece to quantify the respirator fit.

1. General

(a) The employer shall ensure that persons admini stering QNFT are able to calibrate equipment and perform tests properly, recognize in valid tests, calculate fit fact ors properly and ensure that test equipment is in proper working order.

(b) The employer shall ensure that QNFT equipment is kept clean, and is maintained and calibrated according to the manufacturer's instructions so as to operate at the param eters for which it was designed.

2. Generated Aerosol Quanti tative Fit Testing Protocol

(a) Apparatus.

(1) Instrumentation. Aerosol generati on, dilution, and measurement systems using particulates (corn oil, polyethy lene glycol 400 [PEG 400], di-2-eth yl hexyl sebacate [DEHS] or sodium chloride) as test aerosols s hall be used for quantitative fit testing.

(2) Test chamber. The test chamber shall be large enough to permit all test subjects to perform freely all required exer cises without disturbing the test agent concentration or the measurement apparatus. The test chamber shall be equipped and constructed so that theHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 145 test agent is effectively isolated from the ambient air, yet uniform in concentration throughout

the chamber.

(3) When testing air-purifying re spirators, the normal filter or cartridge element shall be replaced with a high efficiency particulate air (H EPA) or P100 series filter supplied by the

same manufacturer.

(4) The sampling instrument shall be selected so that a computer record or strip chart record may be made of the test showing the rise and fall of the test agent concentration with each inspiration and expiration at fit factors of at least 2,000. In tegrators or computers that integrate the amount of test agent penetration leakage into the respirator for each exercise may be used provided a record of the readings is made.

(5) The combination of s ubstitute air-purifying element s, test agent and test agent concentration shall be such that the test subjec t is not exposed in excess of an established exposure limit for the test agent at any time during the test ing process, based upon the length of the exposure and the exposure limit duration.

(6) The sampling port on the test specimen re spirator shall be placed and constructed so that no leakage occurs around the port (e.g., where the respirator is probe d), a free air flow is allowed into the sampling line at all times, and there is no interf erence with the fit or performance of the respirator. The in-mask sa mpling device (probe) shall be designed and used so that the air sample is drawn from the breathing zone of the test subject, midway

between the nose and mouth and wit h the probe extending into the facepiece cavity at least

1/4 inch.

(7) The test setup shall permit the person admin istering the test to observe the test subject inside the chamber during the test.

(8) The equipment generating t he test atmosphere shall mainta in the concentration of test agent constant to within a 10 percent va riation for the duration of the test.

(9) The time lag (interval between an event and the recording of the event on the strip chart or computer or integrator) shall be kept to a minimum. There shall be a clear association

between the occurrence of an event and its being recorded.

(10) The sampling line tubing for the test chamber atmosphere an d for the respirator sampling port shall be of equal diameter and of t he same material. The l ength of the two lines shall be equal.

(11) The exhaust flow from the test chamber shall pass thr ough an appropriate filter (i.e., high efficiency particulate filter) before release.

(12) When sodium chloride aerosol is used, the relative humidity inside the test chamber shall not exceed 50 percent.

(13) The limitations of inst rument detection shall be taken into account when determining the

fit factor.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 146 (14) Test respirators shall be maintained in proper working order and be inspected regularly for deficiencies such as cracks or missing valves and gaskets.

(b) Procedural Requirements.

(1) When performing the initial user seal che ck using a positive or negative pressure check, the sampling line shall be crimped closed in order to avoid air pressure leakage during either of these pressure checks.

(2) The use of an abbreviated screening QLFT test is optional. Such a test may be utilized in order to quickly identify poor fitting respir ators that passed the positive and/or negative pressure test and reduce the am ount of QNFT time. The use of the CNC QNFT instrument in the count mode is another optional method to obtain a quick estima te of fit and eliminate poor fitting respirators before going on to perform a full QNFT.

(3) A reasonably stable test agent concentration shall be measur ed in the test chamber prior to testing. For canopy or shower curtain types of test units, the de termination of the test agent's stability may be established after the test subject has entered the test environment.

(4) Immediately after the subj ect enters the test chamber, t he test agent concentration inside the respirator shall be measured to ensure that the peak penetration does not exceed 5 percent for a half mask or 1 percent for a full facepiece respirator.

(5) A stable test agent concentration shall be obt ained prior to the actual start of testing.

(6) Respirator restraining straps shall not be over-tightened for testing. The straps shall be adjusted by the wearer without assistance from other persons to give a reasonably comfortable fit typical of normal use. The resp irator shall not be adjusted once the fit test exercises begin.

(7) The test shall be terminated whenever any single peak penetration exceeds 5 percent for half masks and 1 percent for full facepiece respir ators. The test subj ect shall be refitted and

retested.

(8) Calculation of fit factors.

(i) The fit factor shall be determined for the quantitative fit test by taking the ratio of the average chamber concentration to t he concentration measured inside the respirator for each test exercise except the grimace exercise.

(ii) The average test chamber concentrati on shall be calculated as the arithmetic average of the concentration me asured before and after each test (i.e., 7 exercises) or the arithmetic average of the concentration measured bef ore and after each exercise or the true average measur ed continuously during the respirator sample.

(iii) The concentration of the challenge agent inside the respirator shall be determined by one of the following methods:Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 147 ( A ) Average peak penetrati on method means the method of determining test agent penetration into the resp irator utilizing a strip char t recorder, integrator, or computer. The agent penetration is determined by an average of the peak heights on the graph or by computer integr ation, for each exer cise except the grimace exercise. Integrators or computer s that calculate the actual test agent penetration into the respirat or for each exercise will al so be considered to meet the requirements of the av erage peak penetration method.

( B ) Maximum peak penetration method mean s the method of determining test agent penetration in the respirator as dete rmined by strip chart recordings of the test. The highest peak penetration for a given exercise is taken to be representative of average penetration into the respirator for that exercise.

( C ) Integration by calculation of t he area under the individual peak for each exercise except the grimace exercise. Th is includes computerized integration.

( D ) The calculation of the overall fit fact or using individual exercise fit factors involves first converting the exerci se fit factors to penetration values, determining the average, and then converti ng that result back to a fit factor. This procedure is descri bed in the following equation:

[A graphic goes here]

Where ff1, ff2, ff3, etc. are the fit factors for ex ercises 1, 2, 3, etc.

(9) The test subject shall not be permitted to wear a half mask or quarter facepiece respirator

unless a minimum fit factor of 10 0 is obtained, or a full facepi ece respirator unless a minimum

fit factor of 500 is obtained.

(10) Filters used for quantitative fit testi ng shall be replaced whenever increased breathing resistance is encountered, or when the test agent has altered the integrity of the filter media.

3. Ambient aerosol condensation nuclei counte r (CNC) quantitative fi t testing protocol.

The ambient aerosol condensation nuclei counter (CNC) quantitative fit testing (Portacount TM ) protocol quantitatively fit tests re spirators with the use of a probe. The probed respirator is only used for quantitative fit tests. A pr obed respirator has a special sa mpling device, installed on the respirator, that allows the probe to sample the air from inside the mask. A probed respirator is required for each make, style, model, and size that the employer uses and can be obtained from the respirator manufacturer or distri butor. The CNC instrument manufac turer, TSI Inc., also provides probe attachments (TSI sampling adapt ers) that permit fit testing in an employee's own respirator. A minimum fit factor pass level of at least 100 is necessary for a half-mask respirator and a minimum fit factor pass level of at least 500 is required fo r a full facepiece negative pressure respirator. The entire screening and testing procedure s hall be explained to the test s ubject prior to the conduct of the screening test.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 148 (a) Portacount Fit Test Requirements. (1) Check the respirator to make sure the sampling probe and line are properly attached to the fa cepiece and that the respirator is fitted with a particulate filter capable of preventing signifi cant penetration by the ambient parti cles used for the fit test (e.g., NIOSH 42 CFR 84 series 100, series 99, or seri es 95 particulate filter) per manufacturer's

instruction.

(2) Instruct the person to be tested to don the respir ator for five minutes before the fit test starts. This purges the ambient particles trapped inside t he respirator and permits the wearer to make certain the respirator is comfort able. This individual shall alre ady have been trained on how to wear the respirator properly.

(3) Check the following condition s for the adequacy of the respirator fit: Chin properly placed; Adequate strap tension, not overly tightened; Fit across nose bridge; Respirator of proper size to span distance from nose to chin; Tendency of the resp irator to slip; Self-observation in a mirror to evaluate fit and respirator position.

(4) Have the person wearing the respirator do a user seal check. If leakag e is detected, determine the cause. If leakage is from a poor ly fitting facepiece, try another size of the same model respirator,

or another model of respirator.

(5) Follow the manufacturer's instructions for operating the Portacount and proceed with the test.

(6) The test subject shall be instructed to perform t he exercises in section I. A. 14. of this appendix.

(7) After the test exerci ses, the test subject s hall be questioned by the test conductor regarding the comfort of the respirator upon comp letion of the protocol. If it has become unacceptable, another model of respirator shall be tried.

(b) Portacount Test Instrument.

(1) The Portacount will automatically stop and calcul ate the overall fit fact or for the entire set

of exercises. The overall fit factor is w hat counts. The Pass or Fail message will indicate

whether or not the test was successful. If t he test was a Pass, the fit test is over.

(2) Since the pass or fail crit erion of the Portacount is userprogrammable, the test Shell shall ensure that the pass or fail criterion meet the require ments for minimum respirator performance in this Appendix.

(3) A record of the test needs to be kept on file, assuming the fit test was successful. The

record must contain the test s ubject's name; overall fit factor; make, model, style, and size of respirator used; and date tested.

4. Controlled negative pressure (CNP) quantitative fit te sting protocol.

The CNP protocol provides an alte rnative to aerosol fit test met hods. The CNP fit test method technology is based on exhausting ai r from a temporarily sealed resp irator facepiece to generate and then maintain a constant negative pressure insi de the facepiece. The rate of air exhaust is controlled so that a constant negative pressure is ma intained in the respirator during the fit test. TheHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 149 level of pressure is selected to replicate the mean inspiratory pressure that causes leakage into the respirator under normal use conditions. With pressure held constant, air flow out of the respirator is equal to air flow into the respirator. Therefore, measurement of the exhaust stream that is required to hold the pressure in the temporarily sealed respir ator constant yields a direct measure of leakage air flow into the respirator. The CNP fit test method measures leak rates through the facepiece as a method for determining the facepi ece fit for negative pressure resp irators. The CNP instrument manufacturer Dynatech Nevada also provides attach ments (sampling manifold s) that replace the filter cartridges to permit fit test ing in an employee's own respirat or. To perform the test, the test subject closes his or her mouth and holds his/her breath, after which an air pump removes air from the respirator facepiece at a pre- selected constant pressure. The facepiece fit is expressed as the leak rate through the facepiece, expressed as m illiliters per minute. The quality and validity of the CNP fit tests are determined by the degree to which the in-mask pressure trac ks the test pressure during the system measurement time of approximately five seconds. Instantaneous feedback in the form of a real-time pressure trac e of the in-mask pressure is pr ovided and used to determine test validity and quality. A minimum fit factor pass leve l of 100 is necessary for a half-mask respirator and a minimum fit factor of at least 500 is requi red for a full facepiece respirator. The entire screening and testing procedure shall be explained to the test subject prior to the conduct of the screening test.

(a) CNP Fit Test Requirements.

(1) The instrument shall have a non-adjustable test pressure of 15.0 mm water pressure.

(2) The CNP system defaults selected for test pressure shall be set at -15 mm of water (- 0.58 inches of water) and the modeled inspirator y flow rate shall be 53. 8 liters per minute for performing fit tests.

Note:

CNP systems have built-in capability to conduct fit testing that is specific to unique work rate, mask, and gender situations that mi ght apply in a specific workpl ace. Use of system default values, which were selected to represent respirat or wear with medium cartridge resistance at a low-moderate work rate, will allow inter-t est comparison of the respirator fit.) (3) The individual who conducts the CNP fit te sting shall be thoroughly trained to perform the

test.

(4) The respirator filter or cartridge needs to be replaced with the CNP test manifold. The

inhalation valve downstream from the manifold either needs to be temporarily removed or propped open.

(5) The test subject shall be trained to hol d his or her breath for at least 20 seconds.

(6) The test subject shall don the test respir ator without any assistanc e from the individual

who conducts the CNP fit test.

(7) The QNFT protocol shall be followed accordi ng to section I. C. 1. of this appendix with an exception for the CNP test exercises.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 150 (b) CNP Test Exercises.

(1) Normal breathing. In a normal standing positi on, without talking, the subject shall breathe normally for 1 minute. After t he normal breathing exercise, the subject needs to hold head straight ahead and hold his or her breath for 10 seconds dur ing the test measurement.

(2) Deep breathing. In a normal standing positi on, the subject shall breathe slowly and deeply for 1 minute, being careful not to hyperv entilate. After the deep breathing exercise, the subject shall hold his or her head straight ahead and hold his or her breath for 10 seconds during test measurement.

(3)Turning head side to side. Standing in place, t he subject shall slowly turn his or her head

from side to side between the ex treme positions on each side for 1 minute. The head shall be held at each extreme momentarily so the subject can inhale at each side. After the turning head side to side exercise, the subject needs to hold head full left and hold his or her breath for 10 seconds during test meas urement. Next, the subject needs to hold head full right and

hold his or her breath for 10 se conds during test measurement.

(4) Moving head up and down. Standing in place, t he subject shall slowly move his or her head up and down for 1 minute. T he subject shall be instructed to inhale in the up position (i.e., when looking toward the ceiling). A fter the moving head up and down exercise, the subject shall hold his or her head full up and hold his or her breath for 10 seconds during test measurement. Next, the subject shall hold his or her head full down and hold his or her breath for 10 seconds during test measurement.

(5) Talking. The subject shall talk out l oud slowly and loud enough so as to be heard clearly by the test conductor. The subject can read from a prepared text such as the Rainbow Passage, count backward from 100, or recite a memorized poem or song for 1 minute. After the talking exercise, the subject shall hold hi s or her head straight ahead and hold his or her

breath for 10 seconds duri ng the test measurement.

(6) Grimace. The test subject shall gr imace by smiling or frowning for 15 seconds.

(7) Bending Over. The test subject shall bend at t he waist as if he or she were to touch his or her toes for 1 minute. Jogging in place shall be substituted for this exercise in those test environments such as shroud-type QNFT units t hat prohibit bending at the waist. After the bending over exercise, the subjec t shall hold his or her head straight ahead and hold his or

her breath for 10 seconds dur ing the test measurement.

(8) Normal Breathing. The test subject shall remove and re-don the re spirator within a oneminute period. Then, in a normal standing position, without talking, the subject shall breathe normally for 1 minute. After the normal breathing exercise, the subject shall hold his or her head straight ahead and hold his or her breath for 10 seconds du ring the test measurement.

After the test exercise s, the test subject shall be questioned by the test conductor regarding the comfort of the resp irator upon completion of the protocol. If it has become unacceptable, another model of a respir ator shall be tried.

(c) CNP Test Instrument.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 151 (1) The test instrument shall have an effect ive audio warning device when the test subject

fails to hold his or her breath during the test. The test shall be terminated whenever the test subject failed to hold his or her breath. T he test subject may be refitted and retested.

(2) A record of the test sha ll be kept on file, assuming the fit test was successful. The record must contain the test subject's name; overa ll fit factor; make, mode l, style and size of respirator used; and date tested.

Part II. New Fit Test Protocols

A. Any person may submit to OSHA an application fo r approval of a new fit test protocol. If the application meets the follo wing criteria, OSHA will initiate a rulemaking proceeding under section 6(b)(7) of the OSH Act to determine whether to list the new protocol as an approved protocol in this Appendix A.

B. The application must include a detailed description of the proposed new fit test protocol. This application must be su pported by either:

1. A test report prepared by an independent gover nment research laboratory (e.g., Lawrence Livermore National Laboratory, Lo s Alamos National Labor atory, the National In stitute for Standards and Technology) stating that the laboratory has tested t he protocol and had found it to be accurate and reliable; or

2. An article that has been publis hed in a peer-reviewed industrial hygiene journal describing the protocol and explaining how test data support t he protocol's accuracy and reliability.

C. If OSHA determines that additional informa tion is required before the Agency commences a rulemaking proceeding under this section, OSHA wi ll so notify the applicant and afford the applicant the opportunity to submit the supplemental informati on. Initiation of a rulemaking proceeding will be

deferred until OSHA has received and ev aluated the supplemental information.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 152 

### APPENDIX B-1 TO §1 910.134: USER SE AL CHECK PROCEDUR ES (MANDATORY)

The individual who uses a tight-fitting respirator is to perform a user seal check to ensure that an adequate seal is achieved each time the respirator is put on. Either the positive and negative pressure checks listed in this appendix, or the respirator manufacturer's recommended user seal

check method shall be used. User seal checks are not substitutes for qualitative or quantitative fit

tests.

I. Facepiece Positive and/or Negative Pressure Checks

A. Positive pressure check. Close off the exhalation valve and exha le gently into the facepiece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece without any evidence of outward leakage of air at the seal. For most respirator s this method of leak testing requires the wearer to first remove the exha lation valve cover before closing off the exhalation valve and then carefully replacing it after the test.

B. Negative pressure check. Close off the inlet opening of the cani ster or cartridge(s) by covering with the palm of the hand( s) or by replacing the f ilter seal(s), inhale gently so that the facepiece collapses slightly, and hold the breath for ten seconds. The desi gn of the inlet opening of some cartridges cannot be effectively covered with the palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the facepiece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory.

II. Manufacturer's Recommended User Seal Check Procedures

The respirator manufacturer's re commended procedures for performing a user seal check may be used instead of the positive and/or negative pressure check procedures provided that the employer

demonstrates that the manufacturer' s procedures are equally effective.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 153 

### APPENDIX B-2 TO §191 0.134: RESPIRATOR CL EANING PROCEDURES (MANDATORY)

These procedures are provided for employer use when cleaning respir ators. They are general in nature, and the employer as an al ternative may use the cleaning recommendations provided by the manufacturer of the respir ators used by their employees, provi ded such procedures are as effective as those listed here in Appendix B- 2. Equivalent effectiveness simp ly means that the procedures used must accomplish the objectives set forth in Appen dix B-2, i.e., must ensur e that the respirator is properly cleaned and disinfecte d in a manner that prevents damage to the respirator and does not

cause harm to the user.

I. Procedures for Cleaning Respirators

A. Remove filters, cartridges, or canisters. Disassemble fa cepieces by removing speaking diaphragms, demand and pressure -demand valve assemblies, hoses, or any components recommended by the manufacturer. Disca rd or repair any defective parts.

B. Wash components in warm (43 °C [110 °F] ma ximum) water with a mild detergent or with a cleaner recommended by the manufacturer. A stiff br istle (not wire) brush may be used to facilitate

the removal of dirt.

C. Rinse components thoroughly in clean, warm ( 43 °C [110 °F] maximum), preferably running

water. Drain.

D. When the cleaner used does not contain a disi nfecting agent, respirator components should be immersed for two minutes in one of the following:

1. Hypochlorite solution (50 ppm of chlorine) made by adding appr oximately one milli liter of laundry bleach to one liter of water at 43 °C (110 °F); or,

2. Aqueous solution of iodine (50 ppm iodine) m ade by adding approximate ly 0.8 milliliters of tincture of iodine (6-8 grams ammonium and/or pot assium iodide/100 cc of 45% alcohol) to one liter of water at 43 °C (110 °F); or,

3. Other commercially available cleans ers of equivalent disinf ectant quality when used as directed, if their use is recommended or approved by the respirator manufacturer.

E. Rinse components thoroughly in clean, warm (43 °C [110 °F] ma ximum), preferably running water. Drain. The importance of thorough rins ing cannot be overemphasized. Detergents or disinfectants that dry on facepieces may result in dermatitis. In addition, some disinfectants may

cause deterioration of rubber or corrosion of metal parts if not completely removed.

F. Components should be hand-dried with a clean lint-free cloth or air-dried.

G. Reassemble facepiece, replacing filters, cartridges, and canisters where necessary.

H. Test the respirator to ensur e that all components work properly.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 154 

### APPENDIX C TO §1910.134: OSHA RESPIRATOR MEDICAL EVALUATION QUESTIONNAIRE (MANDATORY)

To the employer: Answers to questions in Section 1, and to question 9 in Section 2 of Part A, do not require a medical examination.

To the employee:

Can you read (circle one): Yes/No

Your employer must allow you to answer this questionnaire during normal working hours, or at a time and place that is convenient to you. To maintain your conf identiality, your employer or supervisor must not look at or re view your answers, and your employ er must tell you how to deliver or send this questionnaire to the health care professional who will review it.

Part A. Section 1 . (Mandatory) The following information must be provi ded by every employee who has been selected to use any type of respirator (please print).

1. Today's date:_____

2. Your name:______

_____________________________

3. Your age (to nearest year):_____

4. Sex (circle one): Male/Female

5. Your height: __ft. __in.

6. Your weight: __ lbs.

7. Your job title:

_______________________ _____________

8. A phone number where you can be reached by the health care professional who reviews this questionnaire (include the Area Code): ____________

_______________________

9. The best time to phone you at this number: ______________________

10. Has your employer told you how to contact t he health care professional who will review this questionnaire (circle one): Yes/No

11. Check the type of respirator you will use (you can check more than one category):

a. ___ N, R, or P disposable respirator (filt er-mask, non-cartridge type only).

b. ___ Other type (for example, hal f- or full-facepiece type, power ed-air purifying, supplied-air,

self-contained breathing apparatus).Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 155 12. Have you worn a respir ator (circle one): Yes/No

If "yes," what type( s):________________

_____________________ ______________

Part A. Section 2 . (Mandatory) Questions 1 through 9 below must be answered by every employee who has been selected to use any type of re spirator (please circle "yes" or "no").

1. Do you currently smoke tobacco, or have you smoked t obacco in the last month: Yes/No

2. Have you ever had any of the following conditions?

a. Seizures (fits): Yes/No

b. Diabetes (sugar disease): Yes/No

c. Allergic reactions that interfere with your breathing: Yes/No

d. Claustrophobia (fear of closed-in places): Yes/No

e. Trouble sm elling odors: Yes/No

3. Have you ever had any of the following pu lmonary or lung problems?

a. Asbestosis: Yes/No

b. Asthma: Yes/No

c. Chronic bronchitis: Yes/No

d. Emphysema: Yes/No

e. Pneumonia: Yes/No

f. Tuberculosis: Yes/No

g. Silicosis: Yes/No

h. Pneumothorax (collapsed lung): Yes/No

i. Lung cancer: Yes/No

j. Broken ribs: Yes/No

k. Any chest injuries or surgeries: Yes/No

l. Any other lung problem that you've been told about: Yes/NoHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 156 4. Do you currently have any of the following symptoms of pulmonary or lung illness?

a. Shortness of breath: Yes/No

b. Shortness of breath when walki ng fast on level ground or walking up a slight hill or incline:

Yes/No

c. Shortness of breath when walking with other people at an ordinary pace on level ground:
Yes/No

d. Have to stop for breath when walking at your own pace on level ground: Yes/No

e. Shortness of breath when washing or dressing yourself: Yes/No

f. Shortness of breath that interferes with y our job: Yes/No

g. Coughing that produces phlegm (thick sputum): Yes/No

h. Coughing that wakes y ou early in the morning: Yes/No

i. Coughing that occurs mo stly when you are ly ing down: Yes/No

j. Coughing up blood in the last month: Yes/No

k. Wheezing: Yes/No

l. Wheezing that inte rferes with your job: Yes/No

m. Chest pain when you breathe deeply: Yes/No

n. Any other symptoms that you th ink may be related to lung problems: Yes/No

5. Have you ever had any of the following cardio vascular or heart problems?

a. Heart attack: Yes/No

b. Stroke: Yes/No

c. Angina: Yes/No

d. Heart failure: Yes/No

e. Swelling in your legs or feet (not caused by walking): Yes/No

f. Heart arrhythmia ( heart beating irregularly): Yes/No

g. High blood pressure: Yes/NoHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 157 h. Any other heart problem that you've been told about: Yes/No

6. Have you ever had any of the following cardiovascular or heart symptoms?

a. Frequent pain or tight ness in your chest: Yes/No

b. Pain or tightness in your chest during physical activity: Yes/No

c. Pain or tightness in your ches t that interferes wit h your job: Yes/No

d. In the past two y ears, have you noticed your heart skipping or missing a beat: Yes/No

e. Heartburn or indigestion t hat is not related to eating: Yes/No

f. Any other symptoms that you think may be related to heart or circulation problems: Yes/No

7. Do you currently take medication for any of the following problems?

a. Breathing or lung problems: Yes/No

b. Heart trouble: Yes/No

c. Blood pressure: Yes/No

d. Seizures (fits): Yes/No

8. If you've used a respirator, have you ever had any of the following problems? (If you've never used a respirator, check the following space and go to question 9:)

a. Eye irritation: Yes/No

b. Skin allergies or rashes: Yes/No

c. Anxiety: Yes/No

d. General weak ness or fatigue: Yes/No

e. Any other problem that interfer es with your use of a respirator: Yes/No

9. Would you like to talk to the health care prof essional who will review this questionnaire about your answers to this questionnaire: Yes/NoHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 158 Questions 10 to 15 below must be answered by every employee who has been selected to use either a full-facepiece respirator or a self-c ontained breathing apparatus (SCBA). For employees who have been selected to use other types of resp irators, answering these questions is voluntary.

10. Have you ever lost vision in either eye (tempor arily or permanently): Yes/No

11. Do you currently have any of the following vision problems?

a. Wear contact lenses: Yes/No

b. Wear glasses: Yes/No

c. Color blind: Yes/No

d. Any other eye or vision problem: Yes/No

12. Have you ever had an injury to your ears, incl uding a broken ear drum: Yes/No

13. Do you currently have any of the follo wing hearing problems?

a. Difficulty hearing: Yes/No

b. Wear a hearing aid: Yes/No

c. Any other heari ng or ear problem: Yes/No

14. Have you ever had a back injury: Yes/No

15. Do you currently have any of the following musculoskeletal problems?

a. Weakness in any of your arms, hands, legs, or feet: Yes/No

b. Back pain: Yes/No

c. Difficulty fully moving your arms and legs: Yes/No

d. Pain or stiffness when you l ean forward or backward at the waist: Yes/No

e. Difficulty fully mo ving your head up or down: Yes/No

f. Difficulty fully moving your head side to side: Yes/No

g. Difficulty bending at your knees: Yes/No

h. Difficulty squa tting to the ground: Yes/No

i. Climbing a flight of stairs or a ladder carrying more than 25 lbs: Yes/NoHydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 159 j. Any other muscle or skeletal problem that interferes with using a respirator: Yes/No

Part B Any of the fo llowing questions, and other questions not listed, may be added to the questionnaire at the discr etion of the health care professiona l who will review the questionnaire.

1. In your present job, are you wo rking at high altitudes (over 5,000 f eet) or in a place that has lower than normal amounts of oxygen: Yes/No

If "yes," do you have feelings of dizziness, shortness of breath, pounding in your chest, or other symptoms when you're working u nder these conditions: Yes/No

2. At work or at home, have you ever been ex posed to hazardous solvents, hazardous airborne chemicals ( e.g. , gases, fumes, or dust), or have you come into skin contact with hazardous
chemicals: Yes/No

If "yes," name the chemicals if you know them:______________________

______________

3. Have you ever worked with any of the materials, or under any of the conditions, listed below:

a. Asbestos: Yes/No

b. Silica ( e.g. , in sandblasting): Yes/No

c. Tungsten/cobalt ( e.g. , grinding or welding this material): Yes/No

d. Beryllium: Yes/No

e. Aluminum: Yes/No

f. Coal (for ex ample, mining): Yes/No

g. Iron: Yes/No

h. Tin: Yes/No

i. Dusty environments: Yes/No

j. Any other haz ardous exposures: Yes/No

If "yes," describe these exposures:___________

____________________________________

______________
________________________ _______________________ _____________

4. List any second jobs or side bus inesses you have:_______

____________________ ________Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 160 5. List your previous occupati ons:________________________________________

__________

6. List your current and previous hobbies:____________________

________________________

7. Have you been in the military services? Yes/No

If "yes," were you exposed to biological or chemical agents (either in training or combat): Yes/No

8. Have you ever worked on a HAZMAT team? Yes/No

9. Other than medications for breathing and l ung problems, heart trouble, blood pressure, and seizures mentioned earlier in this questionnaire, are you taking any other medications for any reason (including over-the-count er medications): Yes/No

If "yes," name t he medications if you know them:____________________

______________

10. Will you be using any of the follo wing items with your respirator(s)?

a. HEPA Filters: Yes/No

b. Canisters (for example, gas masks): Yes/No

c. Cartridges: Yes/No

11. How often are you expected to use the respirat or(s) (circle "yes" or "no" for all answers that apply to you)?:

a. Escape only (no rescue): Yes/No

b. Emergency rescue only: Yes/No

c. Less than 5 hours per week: Yes/No

d. Less than 2 hours per day: Yes/No

e. 2 to 4 hours per day: Yes/No

f. Over 4 hours per day: Yes/No

12. During the period you are using the re spirator(s), is your work effort:

a. Light (less than 200 kcal per hour): Yes/No

If "yes," how l ong does this period last duri ng the average shift:______hrs.______mins.

Examples of a light work effort are sitting while writing, typing, drafti ng, or performing light assembly work; or standing while operating a drill press (1-3 lbs.) or controlling machines.Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 161 b. Moderate (200 to 350 kcal per hour): Yes/No

If "yes," how l ong does this period last during the average shift:______hrs.______mins.

Examples of moderate work effort are sitting while nailing or filing; driving a truck or bus in urban traffic; standing while drilling, nailing, per forming assembly work, or transferring a moderate load (about 35 lbs.) at trunk level; walking on a level surface about 2 mph or down a 5-degree grade about 3 mph; or pushing a wheelbarrow with a heavy load (about 100 lbs.) on a level surface.

c. Heavy (above 350 kcal per hour): Yes/No

If "yes," how long does this per iod last during the aver age shift:______hrs.______mins.

Examples of heavy work are lifting a heavy load (about 50 lbs.) from the floor to your waist or shoulder; working on a loading dock; shoveling; standing while bricklaying or chipping castings; walking up an 8-degree grade about 2 mph; climbing stairs with a heavy load (about 50 lbs.).

13. Will you be wearing protective clothing and/or equipment (other t han the respirator) when you're using your respirator: Yes/No If "yes," describe this protec tive clothing and/or equipment:_____

__________________________________________ _____________________ _______________

14. Will you be working under hot conditions (temperature exceedi ng 77 °F): Yes/No

15. Will you be working under humid conditions: Yes/No

16. Describe the work you'll be doing while you're using your respirator(s): ___________________

__________________________________________ _____________________ _______________

__________________________________________ _____________________ _______________

17. Describe any special or hazardous conditions you might encounter when you're using your respirator(s) (for example, confined spac es, life-threatening gases ): _________

_______________

__________________________________________ _____________________ _______________

__________________________________________ _____________________ _______________

18. Provide the following information, if you know i t, for each toxic substance that you'll be exposed to when you're using your respirator(s):

Name of the firs t toxic substanc e:______________

_______________

Estimated maximum ex posure level per shift:____________________Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 162 Duration of expo sure per shift

________________________________

Name of the seco nd toxic substanc e:_________________

_________

Estimated maximum ex posure level per shift:____________________

Duration of expo sure per shift:

______________________ _________

Name of the thir d toxic substanc e:_____________

_______________

Estimated maximum ex posure level per shift:___________________

Duration of expo sure per shift:

______________________ _________

The name of any other toxic substances t hat you'll be exposed to while using your respirator:

_______________
__________________ __________________________ ______________

_______________
__________________ __________________________ ______________

19. Describe any special responsibilities you'll have wh ile using your respirator (s) that may affect the safety and well-being of others (for example, rescue, secu rity): ________

__________________

_____________________
__________________ _______________________ ____________Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 163 

### APPENDIX D TO §1910.134 (MANDATORY ) INFORMATION FOR EMPLOYEES USING
RESPIRATORS WHEN NOT REQU IRED UNDER THE STANDARD

Respirators are an effective method of protection against des ignated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoi d exposures to hazards, even if the amount of

hazardous substance does not exceed the limits set by OSHA standards. If yo ur employer provides respirators for your voluntary use, of if you provide your own respirator, you need to take certain precautions to be sure that the respir ator itself does not present a hazard.

You should do the following:

1. Read and heed all instructions provided by the manu facturer on use, maintenance, cleaning and care, and warnings regarding th e respirators limitations.

2. Choose respirators certified fo r use to protect against the contam inant of concern. NIOSH, the National Institute for Occupationa l Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A l abel or statement of certification should appear on the respirator or respirator packaging. It will tell you what the re spirator is designed for and how much it will protect

you.

3. Do not wear your respirator into atmospheres containing contaminants for wh ich your respirator is not designed to protect against. For example, a resp irator designed to filter dust particles will not protect you against gases, vapors, or very sm all solid particles of fumes or smoke.

4. Keep track of your respirat or so that you do not mistakenl y use someone else's respirator.

[63 FR 1270, Jan. 8, 1998; 63 FR 20098, 20099, Apr. 23, 1998]Hydrogen Sulfide Contingency Plan Chukchi Sea, Alaska

Shell Gulf of Mexico Inc. May 2011 164 

### SECTION E

DRAWINGS