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Audit of maintenance management on Valhall

Audit: During the period 2 - 4 June 2008 the Petroleum Safety Authority Norway (PSA) conducted an audit of maintenance management in BP Norge AS (BPN), including the use of economic empirical data. During the audit, we concentrated on Valhall, including Valhall Redevelopment (VRD). We identified several non-conformities in relation to the regulatory requirements.

Background for the audit
The PSA is to set standards for and follow up to ensure that the players in the petroleum activities maintain high standards as regards health, safety and the environment, thereby contributing towards creating the greatest possible values for the Norwegian society.

The follow-up shall be system-oriented and risk-based, and be a supplement to the follow-up carried out by the industry itself.

Chapter 4.12.2 of Storting White Paper No. 7 (2001-2002) relating to health, safety and environment in the petroleum activities includes the following wording regarding maintenance management:

"The authorities feel that it is necessary to further develop management models for operations and maintenance in cooperation with the industry, in order to ensure a joint effort to strengthen the quality of maintenance in the petroleum activities through, inter alia, further development of methods and technologies, competence enhancement and research."

Chapter 5.4 of Storting White Paper No. 12 (2005-2006) relating to health, safety and the environment in the petroleum activities points out that deficient maintenance may increase the risk of major accidents, injuries and incidents, and the White Paper refers to a rather comprehensive review of audit reports which shows a relatively large share of non-conformities in relation to the regulatory requirements. This includes deficiencies in the prioritising of maintenance, assessment of critical factors, follow-up of temporary equipment, unsatisfactory documentation and outstanding maintenance of safety-critical equipment. Furthermore, in some cases the competence relating to maintenance management was inadequate.

Current requirements related to maintenance management are specifically stipulated in the Activities Regulations and the Management Regulations.

Purpose of the audit
The purpose of the audit was to

  • investigate whether BPN conducts classification of systems and equipment in accordance with current regulatory requirements and accepted standards, cf. Chapter IX of the Activities Regulations relating to maintenance,
  • evaluate BPN's use of this classification in their maintenance management,
  • examine to what extent economic empirical data/quality costs associated with deficient maintenance are recorded and used to improve maintenance management.

Result of the audit
The results are based on the presentation of elements in BPN's management systems and interviews with selected personnel, with subsequent verification of the governing documents and systems for conducting maintenance on BPN's installations in Norway, including existing and new facilities on Valhall.

BPN does not sufficiently fulfil all requirements in the regulations relating to classification of equipment and to the use of this classification.

Most of our observations are characterised as non-conformities in relation to the regulatory requirements, and they grouped under the following main areas:

  • insufficient method for classification of systems and equipment,
  • missing documentation of compliance with the regulatory requirements,
  • missing classification of systems and equipment,
  • missing maintenance program particularly for safety-critical and production-critical equipment,
  • insufficient use of classification when choosing and prioritising maintenance,
  • insufficient status for carrying out the maintenance,
  • missing evaluation of maintenance effectiveness.

Some potential improvements were also observed.