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Audit of the "Valhall Redevelopment Project"

During the period 24 April - 24 May 2007, the Petroleum Safety Authority Norway (PSA) conducted two audits aimed at BP. The audits were related to process design and to safeguarding of working environment factors - both for the "Valhall Redevelopment Project" (VRD).

Both audits were conducted as independent audits with a joint start-up meeting with BP and at the contractor's premises, and otherwise with parallel implementation of conversations and verifications at the contractor's premises.

Background for the audit
BP submitted a Plan for Development and Operation (PDO) for VRD to the Ministry of Petroleum and Energy on 21 March2007. The plan includes building a new process and living quarters platform (PH) on the Valhall field, as well as extensive modifications to existing facilities.

Engineering of the process plant for the new facility is being carried out for BP by Mustang Engineering in Houston, USA. Engineering of the living quarters module is being done by Fabricom in Stavanger. The plan is to commence construction of the modules during the fourth quarter of 2007, with start-up of PH planned for the fourth quarter of 2010.

The PSA is to be a driving force to ensure that the industry improves its management of factors that can have an impact on the risk of major accidents. The design of the process plant is an important premise as regards the risk of major accidents for a facility. Therefore, the PSA wants to evaluate management-related factors linked to the design of the process plant on PH.

Good management of the working environment in new projects is important in order to achieve good working environment conditions and avoid employees being subjected to health risks.

Purpose of the audit
The purpose of the audit activities was to evaluate how BP plans, implements and follows up the project as regards regulatory requirements. The audit evaluated factors including:

  • Risk management
  • Handling of nonconformities
  • Establishment of appropriate management systems for follow-up as regards process and working environment
  • Follow-up of competence
  • Change management
  • Understanding of the requirements for process design and working environment on the part of the various players involved.

Result - audit of process design
Potential for improvement was identified as regards knowledge of the Norwegian HSE regulations among project personnel. While knowledge regarding the content of the NORSOK standards was good, there was generally little knowledge about the HSE regulations among the project personnel. Specific examples regarding design stated in the guidelines to the regulations were not known in the process discipline.

The content of the quality control of products was unclear, both internally within the process discipline and between the various disciplines. Checklists did exist in Mustang Engineering's system, but they were not used, nor was the project aware of them. The personnel in BP and Mustang Engineering had differing opinions as to whether the system for quality control of products in the project functioned as intended.

The role and responsibility of the process discipline in the various work processes was not very visible, and was in part unclear, with conflicting descriptions given in the project's governing documents.

As regards positive observations, we would refer to the change management system for safety-related factors, which we followed up in this audit. A great deal of attention had been paid to this in the project, and in this area, the project was able to demonstrate a thorough system for following up and documenting changes.

We focused on the design of the flare system, which is an important safety system on the facility. It was apparent that thorough analyses had been made of risk factors linked to this system through HAZOP* and evaluation of audit findings.

*HAZOP (Hazard and Operability Studies)
HAZOP is a systematic method of studying how deviations from the terms of construction for a system can arise, and whether these deviations can entail increased risk.

Result - audit of safeguarding of working environment factors
The audit identified one nonconformity linked to the fact that sufficient manning and competence was not ensured in the area of working environment in the project, neither for Mustang nor for BP.

The process module is based on many equipment packages from different subcontractors. The project is facing a period of many working environment activities linked to follow-up of the equipment packages and layout of the process module. Our assessment is that the project had not secured sufficient specific working environment competence to safeguard these activities in accordance with the regulations.

It emerged during the interviews that materials handling and noise are regarded as being the greatest working environment challenges. Our impression is that these challenges were known, and that they received attention in the project.

The audit identified two improvement areas linked to the following circumstances:

  • Project documentation
  • Follow-up of suppliers.

Positive observations:

  • During the audit, it was our impression that there was focus on the working environment, and that working environment factors were assigned priority in the project.
  • The personnel we interviewed exhibited generally good knowledge of the requirements in relevant working environment standards.
  • BP had supplied personnel with operational experience to the project located in Houston. These personnel contributed to functional and practical solutions.
  • The planned living quarters appeared to provide good, functional solutions.
  • Several useful tools were established and used in the project, such as PIMS and Citadon. A 3-D model was also established that could be opened on individual's PCs, and provided rapid navigation. This made it possible to review the modules in different contexts, including offshore and in meetings between Stavanger and Houston.

Contact person in the Petroleum Safety Authority Norway:
Mike Theiss