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Audit of 2/4J - capacity upgrading and measures against gas leaks

During the period from 21 October to 5 November 2003 the Norwegian Petroleum Directorate (NPD) conducted an audit concerning ConocoPhillips Norge and the production facilities on 2/4J.

Background for the audit:

Ekofisk 2/4J has been subject to several capacity upgrades, both in the actual project phase and later through modifications and adaptations to the facilities on the installation. Further upgrades are planned in connection with the Ekofisk Growth project.

The appointment letter from the Ministry of Labour and Government Administration states that the NPD is to follow up the players to ensure that they facilitate and maintain technical integrity on their installations.

The NPD must also follow up the measures implemented by the players to avoid hydrocarbon leaks (HC leaks). our follow-up activities are to be based on experiences from previous audits and the annual risk level report that particularly focuses on hydrocarbon leaks.

The NPD's strategic plan 2002 -2004 emphasizes that we are to highlight good safeguarding of HES, which is an important element in the value creation chain.

Purpose of the audit:

The purpose of the audit was to ensure that the operation of the process facilities and the upgrading of their capacity on Ekofisk 2/4 J had been and would be implemented in a safe manner and in accordance with the regulatory requirements.

Ensure that the prerequisites from the design phase were complied with in the operating phase (ref. risk analysis).

Contribute to reducing the number of gas leaks. As gas leaks are a significant contributor to the risk of major accidents it is important that the operator has continuous focus on this area.

Verify that the operator follows up its own plans to prevent accidental discharges of hydrocarbons.

Result of the audit:

Our main impression is that modifications / capacity upgrades on Ekofisk 2/4J have been and are being planned and implemented in a controlled manner. It is our impression that operating personnel are sufficiently involved at an early stage to ensure that operating expertise and experience are taken into consideration in the projects.

The NPD has also noted that the message from management on board that one always has time to work safely, has been clearly communicated and understood in the organization.

It is also the NPD's impression that results from risk analyses have not been used sufficiently as contributions to decision, and that deviations from regulations are not prioritized in this connection.

Hydrocarbon leaks are reported as undesirable incidents in SAP. We have noted that ConocoPhillips has changed the criteria for which incidents are to be registered electronically. Only incidents with a certain level of criticality are now entered into SAP.

The two last years relatively few incidents linked to hydrocarbon leaks have therefore been registered in SAP.

The larger number of near incidents registered with 4R (register-react-report-reduce) tags, are only treated as individual incidents and are not assessed systematically with regard to identification of coinciding underlying causes.

Contact person in the PSA:
Mike Theiss