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Audit of follow-up and use of risk analyses at Nyhamna

In the period 9-11 May 2007, the Petroleum Safety Authority Norway carried out a verification activity at Norsk Hydro's facility at Nyhamna as part of the audit of follow-up and use of risk analyses in connection with the start-up and operation of the Ormen Lange facility. We identified one non-conformity related to the highlighting, dissemination and follow-up of the risk and emergency preparedness analysis.

Nyhamna (kilde: Hydro)

The facility at Nyhamna (Source: Hydro)

Background for the audit
Section 13 of the Management Regulations relating to general requirements for analyses specifies that it must appear clearly which conditions, assumptions and limitations apply to each analysis carried out.

Furthermore, the section specifies that the analysis must be updated when changes in the conditions, assumptions and limitations, individually or in total, affect the result of the analyses, or when new knowledge exists which is of importance to the results of the analysis. The Section 13 requirements indicate that the person responsible must know, understand and properly follow up the assumptions and conditions used as a basis for the analyses made.

Professional competence and proper knowledge of systems and equipment, as well as relevant assumptions and limitations in the given design solution, are prerequisites for being able to manage and carry out operation and maintenance activities in a prudent manner.

It is also important to understand the risk inherent in carrying out the activities, including potential consequences of deficient planning and/or incorrect implementation, in order to handle irregular and undesirable situations in the best possible manner.

Purpose of the audit
The main purpose of the audit was to assess how the requirements in Section 13 of the Management Regulations have been handled, and what plans have been made to handle/follow-up these requirements during the operating phase at the facility at Nyhamna.

Other purposes of the audit included assessment of the competence and competence requirements in the operations organisation at Nyhamna, as well as establishing an understanding of who carries out full-scale testing of safety-critical systems at the facility and how this is (planned) carried out.

Result of the audit
The verification was carried out as planned, with conversations and verifications at the facility.

In our view, much good work has been done in the project to establish systems and tools to follow up important analyses (and their presumptions and assumptions) in the operation of the facility. The main challenge is to ensure sufficient training, knowledge and ownership of the various systems to ensure that they are used in a good and intended manner when the facility commences operation.

We identified one non-conformity related to the highlighting, dissemination and follow-up of the risk and emergency preparedness analysis (SEPA). Some areas of improvement were also identified in relation to completion and highlighting of systems and tools contributing to and/or forming the basis for safe operation of the facility, and to the safeguarding of the competence and risk understanding of the personnel prior to start-up of the facility.

We noted that a lot of work remains to be done in areas such as: Training in connection with the facility's barriers, training in administrative systems, taking over packages/systems from commissioning, etc. We see that many systems are now about to be put to use (e.g.: AT, SJA, FSR, Omnisafe, PIMS, HSE-case), and that training is needed and roles must be clarified.

In our view, there will be challenges related to ensuring that sufficient time is set aside for these and other tasks related to the take-over and preparation for start-up of the facility. We assume that Hydro's terms for safe start-up of the facility include assessments related to the status of the issues mentioned above.

Contact person in the Petroleum Safety Authority Norway:
Mike Theiss