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Audit at the Mærsk Guardian - conditions related to Acknowledgement of Compliance (AoC)

From 22 to 24 January 2007, the Petroleum Safety Authority Norway (PSA) conducted verification activities on the drilling facility Mærsk Guardian. The activities were concentrated on conditions related to emergency preparedness, drilling and wells, cranes, lifting equipment and maintenance. The audit was conducted by means of inspection of records, conversations and verifications on the facility.

Background for the audit
The Mærsk Guardian is a jackup drilling facility built in 1986. The facility has previously operated on the Norwegian shelf and obtained an AoC on 1 Nov. 2002. Since then, the facility has been laid up or in operations abroad. The facility is now returning to the Norwegian shelf for drilling work for BP and other operators.

During the audit the Mærsk Guardian was docked at a shipyard in Rotterdam to undergo necessary maintenance and upgrading.

Purpose of the audit
The purpose of the audit was to verify that management systems and technical conditions regarding emergency preparedness, lifting operations, maintenance and drilling on the Mærsk Guardian comply with the regulatory requirements.

The verification was conducted based on a previous AoC application and follow-up, as well as information received in connection with application for consent from BP, and information from Maersk Contractors Norge AS (MCN) at meetings and onboard the facility in connection with the verifications.

Result of the audit
During the audit the facility was undergoing rebuilding, upgrading and necessary maintenance work, following several years of drilling in foreign provinces.

We identified a series of new deviations and conditions with room for improvement in all the subject areas that were verified. The drilling contractor had not previously informed the authorities of these deviations.

Det Norske Veritas (DNV) has previously, on behalf of MCN, carried out verifications to compare the state of the facility with Norsok standard D-001. This inspection resulted in 37 new deviations. The PSA has not received any application for exemption with respect to any of these conditions, nor for any of the conditions found by BP during their audit when hiring the facility.

In this connection, we refer to the letters from the NPD concerning "Mobile drilling facilities that have been laid up or are operating on continental shelves abroad", dated 6 March 2003, "Mobile facilities that are laid up" dated 25 May 2003 and "Exceptions/deviations on mobile drilling facilities" dated 25 September 2002. These letters describe the requirements and commitments that are incumbent on the owner of facilities with an AoC.

The PSA cannot see that these commitments have been sufficiently attended to at the Mærsk Guardian.
Facility maintenance is among the obligations inherent in an AoC. These responsibilities had not been sufficiently attended to at the Mærsk Guardian, cf. Ch. 5.2 of the report. The PSA have noticed several cases where Mærsk facilities with an AoC leave the Norwegian shelf, and do not carry out the required maintenance. This results in a backlog of planned maintenance.

Concerning the National crane, we are of the opinion that the crane is not fit for use.

The PSA noted that a large part of the crew had only been onboard for a short period of time, and therefore had limited knowledge of the facility, systems and equipment. This was true for existing as well as new equipment. In addition, no training and inadequate training of the crew was uncovered.
We also refer to our letter dated 26 January 2007 concerning the deficient attention to the preconditions for an AoC, and the further handling of the matter.

During our audit onboard we recorded situations that are not, in our opinion, safe.

Contact person in the Petroleum Safety Authority
Mike Theiss