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Notification of order after audit of prevention of hydrocarbon leaks on Valhall

The Petroleum Safety Authority Norway (PSA) has conducted an audit of prevention of hydrocarbon leaks on the Valhall field (photo). The audit revealed two nonconformities in relation to the regulations, one of which is of such a nature that we are hereby issuing a notification of order.

On 18-19 May, as well as in the period 31 May - 2 June 2005, we conducted an audit of BP's follow-up and prevention of hydrocarbon leaks on the Valhall field. The audit included both conversations with personnel in the land organization, as well as a visit to the Valhall field.

Background for the audit
Hydrocarbon leaks are one of the types of incidents that make the greatest contribution to the risk of lives being lost in the event of major accidents. The PSA focuses on this risk of major accidents through these types of audits aimed at several operating companies.

OLF's gas leak reduction project (GaLeRe) has established an objective of a 50 percent reduction in the number of hydrocarbon leaks >0.1 kg/s on the Norwegian shelf by the end of 2005.

This project has also made a number of recommendations linked to reducing the risk of hydrocarbon leaks, and we want to follow up how the operators work with these recommendations.

This audit has also focused on monitoring diffuse hydrocarbon leaks.

Objective of the audit
There are a great number of elements that are important in relation to preventing hydrocarbon leaks. In this audit, we have primarily focused on following up incidents and use of historical incidents in the preventive work.

The objectives of the audit were as follows:

  • To verify that BP ensures that incidents involving hydrocarbon leaks on Valhall are followed up in accordance with BP's internal requirements and applicable regulations.
  • To obtain an overview of how BP uses experience from incidents in the preventive safety work, and evaluate this in relation to applicable regulations.

Result of the audit
A nonconformity has been identified in connection with the established system for maintaining documentation for operation. This is not followed up in an adequate manner to ensure that documentation for operation is always up-to-date in the paper files on the field.

A potential for improvement has also been identified in relation to evaluating the suitability of the system established for such maintenance of the documentation for operation.

A nonconformity has been identified that relates to a comprehensive overview of all active nonconformities on the field, as well as an improvement item that relates to registration of nonconformities.

BP has introduced a leakage log on Valhall in which all hydrocarbon leaks are to be registered. Diffuse leaks that do not require immediate measures shall be monitored and their status recorded continuously in the leakage log. This appears to be a useful tool for detecting potential development of diffuse hydrocarbon leaks.

BP has introduced a system called GRACE, in which various courses of events are described and illustrated. The system also contains a description of the causes of failures and the consequences of the incident. There were examples of incidents related to hydrocarbon leaks in this system. This system is used to some extent in connection with planning work on the facilities, and the perception is that it is useful to focus on hazard elements and increasing understanding of risk in the organization.

A hydrocarbon leak group has been set up in the land organization whose mandate is to identify trends and analyze data from hydrocarbon leaks in order to understand the causal factors in relation to such incidents.

It is our impression that this group has not yet prioritized this work, and that it so far has focused on following up the recommendations from OLF's gas leak reduction project (GaLeRe).

We have seen examples indicating that BP Norge has been active as regards utilizing experience gained from incidents involving other operators. Measures have been implemented as a result of the fatal incident on the Shell-operated Brent Bravo field on the British shelf in 2003.

Improvement items have also been identified as regards using historical incidents in the preventive work, as well as measuring the effect of measures implemented after incidents.

Notification of order
The audit revealed two nonconformities with the regulations. The nature of one of these nonconformities is such that we are issuing notification of the following order:
Pursuant to Section 18 of the Activities Regulations relating to start-up and operation of facilities, BP is ordered to ensure that governing documents for operation - including P&ID and C&E diagrams ? are maintained in such a way that ensures that an up-to-date version is always accessible and that operations personnel are aware of such documents.

The order also includes identifying the cause(s) of why the existing system for updating documentation for operation is not fully observed in the Valhall organization.

The deadline for implementing the activities encompassed in the order is set at three weeks after the order is issued. A description of the measures implemented shall be provided to the Petroleum Safety Authority Norway, either in the form of a letter or by means of a meeting.

Any comments regarding the notification must be received by 15 July 2005.

Contact in the Petroleum Safety Authority Norway:
Inger Anda,
Press spokeswoman
Tel.: +47 970 54 064
E-mail: inger.anda@ptil.no