Carried out from 25 September to 5 October 2018, the audit 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.
The results build on Aker BP’s presentations during the audit, a review of operating and governing documentation, interviews, and verifications on Ula. The PSA also ran spot checks with the systems for managing risk, nonconformities and maintenance.
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.
Ula P has 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 has stated that it cannot document the consequences of a liquid fire after five minutes. The PSA’s view is therefore that the requirement to evacuate within five minutes does not represent a robust measure given the uncertainty about the consequences of a fire.
The company gives great emphasis to establishing centralised work processes and a common framework for risk, barrier and maintenance management. The PSA finds that the company gives less weight to completion and implementation at 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 is 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 organisation.
A barrier strategy and updated performance standards are needed for Ula. These will provide an important basis for meeting Aker BP’s own performance requirements with regard to knowledge of barriers, barrier management and facility-specific conditions related to major accident risk. See the Management of Major Accident Risk document. The company has conducted an internal audit during 2018, where a lack of training in barriers and barrier management in accordance with its own requirements was registered as a finding.
Where maintenance is concerned, the facility shows 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 prioritising 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. The PSA cannot see that lessons from the Ivar Aasen audit have been communicated through the organisation to Ula.
A number of examples of inadequate follow-up of nonconformities related to requirements both in the HSE regulations and at the company itself were also found. In the PSA’s view, inconsistent use of the systems for registering and following up risk, nonconformities and compensatory measures provide an inadequate basis for day-to-day management of major accident risk on Ula. The PSA would question how barrier weaknesses and nonconformities are followed up, assessed and communicated with regard to their overall significance for safety on Ula.
Nonconformities were identified in the following systems and areas:
Two improvement points were also identified in relation to the following systems and areas:
On the basis of the observations made in the audit, Aker BP has now been given notice of an order.
Pursuant to section 69 of the framework regulations on administrative decisions, Aker BP is ordered to do the following.
1. Clarify roles, responsibilities and authority related to barrier management on Ula. See section 6, paragraph 2 of the management regulations on management of health, safety and the environment. See chapter 5.1.3 in the audit report.
2. 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 the following.
a. Establish and implement a barrier strategy and update performance standards. See section 5 of the management regulations on barriers. See chapter 5.1.2 in the audit report.
b. Comply with the company’s own requirements for compliance with the barrier management requirements in the HSE regulations, including the company’s document no 80-00626 Management of Major Accident Risk. See section 6 of the management regulations on management of health, safety and the environment, paragraph 2, litera b of the guideline, and section 5 of the management regulations on barriers.
c. Correct deficiencies related to the identification and follow-up of barriers. See section 5 of the management regulations on barriers, section 45 of the activities regulations on maintenance, and section 47 of the activities regulations on maintenance programme. See chapters 5.1.5, 5.1.6 and 5.1.7 in the audit report.
3. 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. See section 6 of the management regulations on management of health, safety and the environment. Present specific improvement measures and implementation plans, including binding deadlines, the unit responsible for implementation and resources allocated in order to establish the following. See chapters 5.1.1 and 5.1.4 in the audit report.
a. Identification. registration and follow-up of nonconformities and compensatory measures. See section 22 of the management regulations on handling of nonconformities.
b. Use, presentation, updating and follow-up of operational risk analyses. See section 16, paragraphs 2, 3 and 4 of the management regulations.
The deadline for compliance with the order is 1 March 2019. The PSA must be informed when the order has been carried out.
The report contains nonconformities other than those which form the basis for the notice of an order, and the PSA has asked Aker BP to explain no later than 11 January 2019 how these will be dealt with.
The PSA has also requested the company’s assessment of the improvement points observed.
Explanation of the terms “order” and “notice of order”
An order is an administrative decision made pursuant to the regulations. Before the PSA issues an order, it generally sends a "notice of order" to the affected companies.
A notice of order is neither an instrument nor a notice of sanctions, but a step in the PSA’s administrative process in which it requests the party to assess the factual basis. The notice is only a first step before an administrative decision is made.
An order is a strongly preventive instrument which is legally binding on the recipient.
Øyvind Midttun, press contact
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