Norwegian offshore safety body, the Petroleum Safety Authority Norway (PSA), has given a notice of order to Aker BP following an audit of the Ula field in the North Sea offshore Norway.
The PSA said on Monday that the audit was conducted from September 25 to October 5.
It aimed to assess how Aker BP ensures compliance with requirements set by the HSE regulations and the company itself for management of major accident risk, barriers, and maintenance on Ula.
Serious breaches of the regulations were identified, and the company was given a notice of order.
Ula P evacuation issues
Attention offshore was directed primarily at the Ula P production facility with regard both to verifications in the field and spot checks with the management systems.
The PSA said that Ula P had integrity challenges because its structure and process equipment cannot withstand the loads which could arise in the event of a liquid fire.
To compensate for deficient and inadequate passive fire protection, a requirement has been in place since 2008 for Ula P to be evacuated as quickly as possible and within five minutes. Aker BP stated that it could not document the consequences of a liquid fire after five minutes.
The PSA’s view is that the requirement to evacuate within five minutes does not represent a robust measure given the uncertainty about the consequences of a fire.
Risk, barrier, and maintenance management
The PSA found that the company gave less weight to completion and implementation at the facility level and that the division of roles and responsibilities between the Ula business unit and relevant support functions on goals, strategies, plans, and measures for meeting barrier management requirements was unclear on Ula.
Several examples were observed where knowledge was lacking about barriers, barrier management, and facility-specific conditions of significance for major accident risk. Overall, the PSA feels that these indicate a lack of barrier understanding at several levels in the organization.
The safety body added that a barrier strategy and updated performance standards were needed for Ula. These will provide an important basis for meeting Aker BP’s performance requirements regarding knowledge of barriers, barrier management, and facility-specific conditions related to major accident risk.
Where maintenance is concerned, PSA said that Ula showed signs that it was scheduled until recently for shutdown within a few years. Results for several of the maintenance management parameters have exceeded the company’s key performance indicators (KPIs) over a long period.
In the PSA’s view, the company is not prioritizing resources and activities required to ensure that maintenance plans are implemented.
Earlier audits on Aker BP’s Ivar Aasen facility showed nonconformities related to rigsaver shutoff valves, and the same type of observations were also made on Ula.
Non-conformities and improvement points
A number of examples of inadequate follow-up of nonconformities related to requirements both in the HSE regulations and at the company itself were found by the PSA.
The safety watchdog said that inconsistent use of the systems for registering and following up risk, non-conformities and compensatory measures provide an inadequate basis for day-to-day management of major accident risk on Ula.
The non-conformities identified during the audit were the management of major accident risk, barrier management, organization, coordination of roles and responsibilities, a system for dealing with non-conformities, passive fire protection, identification and maintenance of barriers, maintenance, the gas detection system, and equipment not in use.
Two improvement points were also found in relation to safety signs and tagging of equipment and battery bank located close to a flange.
Notice of order
On the basis of the observations made in the audit, PSA gave Aker BP a notice of order.
Aker BP was told to clarify roles, responsibilities, and authority related to barrier management on Ula. The company also has to prepare plans for implementing barrier management and handling of major accident risk on Ula.
These plans must include specific measures, binding deadlines, the unit responsible for implementation and resources allocated in order to achieve an establishment and implement a barrier strategy and update performance standards and comply with the company’s requirements for compliance with the barrier management requirements in the HSE regulations. The third plan must correct deficiencies related to the identification and follow-up of barriers.
The PSA added that Aker BP also needs to review the company’s processes and practice for handling nonconformities and use of risk assessments to ensure an integrated basis for managing major accident risk.
Aker BP was also told to comply with the order by March 2019 1 at the latest. The PSA must be informed when the order has been carried out. As for the non-conformities, Aker BP needs to explain how they will be dealt with by January 11. The PSA also requested the company’s assessment of the improvement points observed.
To clarify, an order is an administrative decision and a strongly preventive instrument which is legally binding on the recipient, in this case, Aker BP. Before the PSA issues an order, it usually sends a notice of order to the affected companies which is neither an instrument nor a notice of sanctions.