The operator, Marathon Petroleum Norge AS (Marathon), did not report the incidents to the Petroleum Safety Authority Norway (PSA) as required under Section 11 of the Information Duty Regulations.
We received information about the incidents from representatives of the safety delegate service on Alvheim on 23 June 2009.
Alvheim FPSO (source: APL)
The flare system is intended to be a secure arrangement for collecting hydrocarbon gas and liquid from blowdown scenarios and pressure bleed-off/venting of equipment.
Gas and/or liquid are routed through the flare stack to the flare drum, where liquid and gas are separated. The gas is routed to the flare and burned. The liquid is pumped from the flare drum back to the process.
Overfilling the flare drum can lead to droplets of liquid being carried to the flare. Very serious situations could result if these droplets are ignited and fall down onto the facility.
Meeting with Marathon
On 26 June 2009, we conducted a meeting with the management of Marathon and operations contractor Maersk Drilling Norge AS (Maersk) in which the companies gave their account of the incidents, how they had handled the incidents so far, and their assessment of the need for further measures.
The other licensees in the production license are ConocoPhillips Skandinavia AS (CoPSAS) and Lundin Norway AS (Lundin), neither of which had been informed about the incidents by Marathon.
Organisation of operations
It is our assessment, based on the information we have received so far, that this issue touches on central factors related to the organisation of operations on Alvheim in general, and factors related to managing major accident risk in particular.
These factors are particularly related to the distribution of roles and responsibility among the players, how interfaces are handled, professional competence and understanding of risk, as well as handling and learning from incidents with major accident potential.
We therefore find it necessary for the licensees to consider whether the selected form of operations the licensees have chosen for Alvheim sufficiently facilitates the proper operation of the facility in general, and management of major accident risk in particular.
Notification of order
With reference to the Regulations relating to health, environment and safety in the petroleum activities (the Framework Regulations), Section 5 relating to responsibility according to these regulations, third subsection, cf. Section 58 relating to individual decisions, we have issued the following notification of order to the Alvheim licensees:
The licensees in the Alvheim licence shall conduct a joint review and evaluation of the framework conditions and form of operations for Alvheim to ensure that the operation of Alvheim can be carried out in a manner which ensures that central requirements in the HSE regulations, including handling of major accident risk, are safeguarded.
This work must be completed and the licensees' conclusions submitted to the PSA by 1 September 2009.
We have asked the licensees to comment on this notification by 30 June 2009.