Report following audit of the hotel facility Service Jack 1
The Petroleum Safety Authority Norway (PSA) has carried out an audit of Service Jack 1 which according to the plan will be used as a hotel facility on the Ekofisk field starting in the autumn of 2010. The audit identified several nonconformities and improvement items.
Service Jack 1 is being built at the Drydock World shipyard in Batam, Indonesia. Service Jack 1 will travel to Norway in the spring of 2010 where new deck cranes, an office module and a larger living quarters module (ALQ) will be lifted onboard the installation.
The completed facility will, according to the current plans, be put into service as a jack-up hotel facility (Jacktel) on the Ekofisk field in the autumn of 2010.
The project is called the JackTel project.
During the period 20 August to 27 August 2009, the Petroleum Safety Authority Norway (PSA) carried out, in agreement with O S M Offshore AS (OSM) as the future AoC applicant, advisory services and early phase follow-up within the technical disciplines technical safety, crane- and lifting operations, working environment and maintenance management related to engineering and construction of the jack-up facility Service Jack 1.
Service Jack 1 is being built at the Drydock World shipyard in Batam, Indonesia. Service Jack 1 will travel to Norway in the spring of 2010 where new deck cranes, an office module and a larger living quarters module (ALQ) will be lifted onboard the installation. The completed facility will, according to the current plans, be put into service as a jack-up hotel facility (Jacktel) on the Ekofisk field in the autumn of 2010. The project is called the JackTel project.
The audit mainly targeted issues related to the management and technical aspects of the Jacktel facility, as well as engineering and arrangement of deck cranes and a new living quarters module (ALQ).
The activities were carried out in the form of interviews and document review at Master Marine's project offices at Lysaker in Oslo, as well as at Drydock World/Master Marine's project office in Singapore and at the Drydock World shipyard in Batam, Indonesia. A subsequent clarification meeting was held at the offices of the PSA on 22 September 2009 related to some issues concerning layout.
The activity will be included as part of the administrative procedure for the future application for an Acknowledgement of Compliance (AoC).
These follow-up activities are regarded by the PSA to be part of a future administrative process for an application for an AoC. OSM will according to the present plans apply to the PSA for an AoC for the facility in the spring of 2010, in connection with a planned operation for ConocoPhillips (COPSAS) on the Norwegian continental shelf. The AoC will be included as part of the documentation in COPSAS' future application for consent for the use of the facility as a hotel facility on the Ekofisk field.
Purpose of the audit
The objective of the activity was primarily to contribute to increasing the understanding of the regulations in the project by providing guidelines and information on some of the challenges which the PSA has experienced during the administrative procedures for previous applications for an AoC for other new-build projects. We have seen the utility value of providing such advice, particularly to new players who are building new facilities at shipyards with little or no experience of Norwegian regulations.
Apart from providing advice, the objective of this activity was to assess established management systems which Master Marine and OSM have used to ensure that technical aspects of the facility, within selected technical disciplines, are maintained according to the applicable regulatory requirements. The activity has included issues related to both engineering, fabrication and final completion of the facility.
Result of the audit
A review of Master Marine’s and Drydock World's management systems uncovered that many project documents were only issued with the document status WO (issued for review or IDC). The degree of completion of the governing documents was only to a limited extent in accordance with the completion degree of the project (progress).
The activity identified that scheduled audits had not been carried out according to the plans of the project. Of a total of 14 scheduled activities, at least six activities had not been carried out.
Furthermore, uncertainties regarding the status and use of various procedures in the project were identified.
A lack of preparation of a working environment program to manage working environment activities, as recommended in the guidelines to the regulations was identified. In general, the project has initiated working environment analyses according to the recommendations in the regulations, but several of the analyses required further follow-up, as a number of issues had not been clarified at the time of the analysis. An organisation and staffing study to specify the staffing level and the extent of the activities in various areas on the facility could not be produced. Such information is necessary to carry out other working environment studies, for example noise prediction for 12-hour noise exposure for individual groups of personnel and chemical risk assessment studies for various personnel groups.
For handling of materials, a ”Material Handling Report”, which will constitute a good basis for achieving good material handling on board the JackTel, had been prepared and the document meets the intentions of the regulations to a large degree. This applies in particular to the facilitation of the cargo deck area and storage deck area for use with offshore cranes. However, during the audit we identified that some obstacles had been built and that the ceiling height was low in some transportation routes. In addition, improvement items were identified, which mainly concern the design of the cargo deck area, lifting through hatches and the design of hatches. However, these are still in the design phase, were being assessed and accordingly not completed.
Within maintenance management, we noted that a final decision regarding the choice of a future maintenance management system had not been made. One consequence of this could be that the maintenance system will not be fully developed and operational for start-up on the Norwegian continental shelf.
For the safety systems in general the preparation of the strategy for fire and explosion protection as well as philosophy documents for the individual systems were being prepared, partially at the same time as the detailed engineering of the systems. The revised documents showed that the regulatory requirements in general had been complied with, but that there were minor nonconformities or improvements items in some areas in relation to the requirements in the regulations. In this regard we noted that although the company in general applies Section 3 of the Framework Regulations and maritime regulations, NORSOK S-001 was used in a few instances without documentation that the requirements in the Norwegian Maritime Directorate’s Fire Regulations had been complied with.
We noted that the recruitment of operational personnel who will work on the facility was slow to get started. At the time of our activity only three of a total of 66 persons had been recruited. This can result in challenges as regards ensuring that the personnel receives the necessary familiarisation and training, and ensuring that the necessary operating experience is considered during the in the construction and completion phase.
Clearer guidelines for safeguarding employee participation in the project were called for.
Please note that this report does not provide a balanced general impression of the condition of the facility and the work in the project. The purpose of our report is only to provide feedback on circumstances which require further attention from the project.
- Nonconformity:Follow-up: Scheduled follow-up activities (audit plan) are not followed.
- In Master Marine's own audit plan for 2009 (HSEQ Audit Plan), 14 activities targeted at the shipyard were planned. At least six of these were not carried out as planned, due to a lack of acceptance from the shipyard management. The issue was addressed by the parties without a solution being reached.
- Nonconformity: Procedures for nonconformities: Lack of familiarity with the project's procedures for nonconformities and different use of procedures
- During the audit it was noted that ”Master Marine Service Jack Project Non-Conformance and Corrective Action Procedure” was not known to or used by the various offices. We were informed that the procedure is only used at the construction site in Batam, while it is not known or not used by the offices in Oslo or in Singapore. Seen in the light of the project's complexity and manner it is managed by means of active use of ”Change orders”, it is vital that all types of procedures are known and used in the entire project.
- Drydock World does not use a separate procedure as regards ”Vendors Documents”
- Improvement items: Insufficient document structure and late preparation of governing project documents Preparation of governing HSE and working environment documents in the project has occured very late in the project implementation. There was a lack of an overall structure as regards the establishment of HSE documents in the project.
- An overall plan and structure for preparation and publishing various project-specific HSE and working environment documents to ensure the necessary design basis, phasing in and necessary input to various HSE studies and activities in the project could not be presented.
- There was a general overall activities plan for the project, with dated activities. This plan had not been incorporated as a governing project document.
- The project's Safety & Working Environment Design Philosophy document (P101-mm-ZZ-SA-xxx-xxxx ) dated 5 June 2009 was not available as a formal, approved document and was prepared very late in the project. The document was published as a draft, revision A0, in spite of the project now being in the construction phase. The document's content did not appear to be a philosophy document, but rather the basis for requirements and design.
- A formal working environment program in the project, as recommended in the guidelines to the regulations, cf. NORSOK S-002 item 4.2.1, was not available.
- A work specification (scope of work) for the individual working environment activities which were to be carried out by Scandpower (hired consultancy services), with information relating to necessary input data and a description of the form of the final deliveries to ensure a necessary basis for further studies, analyses and decisions, could not be presented.
- The project's HSE-Plan (P001-MM-SA-5001) dated 17 August 2009, for the construction, integration and completion phase of Service Jack 1 was only available as a draft. This document appeared to be more of an overall philosophy document than a planning document to describe various HSE activities for the remaining project phases. The document included descriptions of several activities which had already been carried out in the design and engineering phase, without the relevance of these activities to the further phases being evident.
- In general, a number of project documents were only available as drafts with document status A0 (Issued for review or IDC), cf. list of received documents. This is in poor compliance with the project's degree of completion and progress.
- Nonconformity:Unclear requirement basis for MMI issues: It was unclear which specific requirements had been made for information presentation, including specific requirements for presentation of alarm information in control rooms to ensure good man-machine interaction, so that the risk of human errors is minimised.
- Documented requirements related to the above-mentioned issues could not be presented.
- The establishment of verifiable MMI requirements is required in order to carry out a final verification and validation of the selected control room solution, cf. for instance CRIOP methodology.
- Nonconfirmity: Organisation and manning study: An organisation and manning study to acquire information about the localisation of the personnel in areas on the facility, total duration of stay, duration and frequency of activities in various areas of the facility had not been carried out. These are necessary as a basis for selecting design solutions and carrying out various HSE and working environment studies.
- In accordance with NORSOK S-002 Ch. 4.3.3 an organisation and manning study must be carried out in the project as input for selecting design and for conduction of various working environment studies and HSE analyses. This is a necessary basis and data basis for carrying out quantitative risk analyses, noise exposure predictions, access and materials handling analyses, ergonomical analyses and chemical health risk assessments.
- Documented plans in the project for preparing an organisation and manning study as described in NORSOK S-002 were not available.
- We noted that, at the time of our activity, talks between COPSAS and OSM were underway with a view to clarifying the final staffing and organisation of the operation of the Jacktel. Ambiguity in this respect is very unfortunate at this phase of the project, as the results may impact various HSE and working environment studies, referred to above.
- Nonconformity: Lack of noise exposure predication studies: Noise exposure prediction had not been carried out as a basis for design.
- Executed predictions of 12-hour noise exposure for vulnerable personnel groups as recommended by the regulations, cf. NORSOK S-002, appendix H, could not be produced These are studies which it is vital to carry out as early as possible to ensure an acceptable design basis. Noise exposure prediction studies should have been carried out before the project entered the construction phase.
- The project's activity plans did not call for noise exposure prediction studies to be carried out.
- During conversations it emerged that predictions of noise for various personnel groups had not been carried out as a result of lack of accumulation of realistic noise data from equipment suppliers and as a result of lack of realistic length of time various personnel groups spend in various areas on the facility, cf. lack of organisation and manning study. The project is now running a greater risk of having to make expensive changes in a late phase in the project as a result of a lack of this type of data.
- Nonconformity: Insufficient routines for employee participation: Documented guidelines and systems to ensure real employee participation in the project could not be produced.
- Governing documents in the project which clearly described who was given authorization to represent the future employees on the Jacktel to ensure future employees influence over their own work situation within the various core activity areas on the facility could not be presented.
- No formal guidelines for information flow between the project and the elected employee representatives were not in place, ensuring that representatives for the future employees are familiar with core activities where it may be relevant to contribute with experience and knowledge to the project.
- Written documentation which describe specific activities the employee representatives want to partake in could not be produced.
- Nonconformity: Size and location of smoking rooms: For the living quarters section of the facility designed for a maximum of 477 persons, there is only one smoking room, which measures 13.9 m2. This smoking room is very small considering the staffing level of the facility. The location of this smoking area with the door leading directly out into the adjacent coffee bar area with a separate seating area for non-smokers, is unfortunate as smoke easily can enter the smoke-free recreational area.
- Review of layout drawings
- Lack of adequate smoking area may result in smoking occurring in areas where this can be a nuisance and fire hazard.
- Improvement items: Galley layout: a) Galley was not equipped with a separate bakery as recommended in the guidelines to the regulations.
b) The dishwashing area (scullery) is not located with direct access from the galley, which means that some kitchen equipment (glasses, etc.) which cannot be washed in the scrubber must be transported through a serving area to the dishwashing room. This can result in potential hygienic challenges.
- Verification of layout drawings
- Nonconformity: Obstacles in transportation routes: Some transportation routes in the superstructure and hull were designed with thresholds and obstacles with a view to efficient materials handling.
- Some transportation routes were not designed to facilitate safe and efficient materials handling. For example there were some transportation routes which had been designed with
- thresholds, cf. NORSOK C-002 item 7.11: ”All thresholds must be dimensioned to be as low as possible, without deteriorate their capability as regards fire class, noise reduction and ability to stop water penetration. Maximum height between the top of the threshold and the floor level must not exceed 25 millimetres. For doors used for regular transportation of trolleys or fork-lift trucks, thresholds must be designed as to create a minimal obstruction. This can for example be achieved using integrated ramps to compensate for the height of the threshold”.
- obstacles such as steel sections welded in the deck to prevent discharges from machines and other equipment from floating into to the adjacent deck areas (recovery trough). This will make transportation with trolleys more difficult.
- lower than the recommended ceiling height due to protruding main structure, ventilation ducts and cable trays.
- Improvement items: Transportation routes and staircases: Access to station with life raft was not designed for transport of materials.
- Based on the 3D model, we noted that at least one of the areas with life rafts was not designed for easy handling out and in the area for the raft station. In connection with periodic certification the rafts are replaced on a regular basis and the transportation route in and out of the area must go via a staircase. Suitable aids to get the rafts up and down this staircase had not been provided.
- Improvement items: Cargo areas not designed and equipped for safe materials handling: Cargo areas were not designed, facilitated and equipped for safe materials handling.
- During review of the 3D model, we noted that several of the cargo areas were not equipped with protection structure (bumpers) and guide structure for handling cargo. In addition, areas where lifting operations are carried out, were equipped with regular hand rails. These are very susceptible to damage during lifting operations and can potentially fall down to decks below.
- We was also observed exposed cable trays and light fixtures which will be susceptible to damage during lifting operations. Examples of these are on the main loading deck and helicopter fuel storage deck.
- Improvement items:Deck hatches and shafts: Detailing of deck hatches and shafts was insufficiently clarified.
- Conversations on board did not clarify how deck hatches and shafts were planned to be designed and if the cranes would be used to open the deck hatches.
The use of cranes is not a suitable means of opening hinged hatches as these easily can be ripped from their brackets. In addition, shafts must be designed for lifting and designed without obstacles that may cause the cargo getting hooked or cause the cargo to tip and fall down into the shaft.
- Improvement items: Offshore crane: Systems for emergency operations and emergency lowering of offshore cranes was inadequately clarified.
- During the audit we asked what kind of system had had been selected for emergency operation, i.e. emergency operations and emergency lowering of offshore cranes in case of shutdown of the facility's main power. The project was unable to give an account of this. We are not familiar with any requirements being made for how quickly such a system can become operational. This is particularly important in regards to emergency operation with lifting of personnel.
- Improvement items: Lifting with offshore cranes through hatches: Storage areas which were intended for the use of offshore cranes through hatches, were not designed for safe materials handling.
- Use of offshore cranes through hatches is regarded as blind lifts. If lifting operations on occasion are to be carried out through hatches, safe operations must be facilitated. This entails for example that shafts are designed so that cargo cannot strike obstacles such as protruding frames, cable trays or similar objects. This so that cargo is not hooked or wedged during lowering or hoisting so that cargo tips or is ripped from the crane hook. In addition, it must be possible to locate personnel in a safe position during the lifting operation.
- Improvement items: Maintenance management system: Final decision regarding selection of maintenance management system had not been made:
- OSM had not decided which maintenance management system is to be used on board the facility. Due to this the work to classify, prepare maintenance programs, carry out criticality analyses, etc. had not progressed much. The result can be that the maintenance management system is not operational upon the start-up of activities on the Norwegian continental shelf.
- Improvement items: Labelling of equipment: Lack of labelling of equipment
- Equipment installed on board and in the warehouse was not labelled (tag)
- Identification of equipment was done using serial numbers from the equipment suppliers
- Nonconformity: Receiving inspection and preservation: Different use and degree of detailing in preservation procedures
- We were informed that the shipyard used its own preservation procedure and not Master Marine ‘spreservation procedure. The procedure used was not as comprehensive and detailed
- Upon receipt of equipment there was no checking whether the number was correct or if the equipment had faults or defects. This was not in accordance with the company’s procedures
- Some of the equipment installed on board was very poorly preserved. During the audit, grinding and welding was carried out in the immediate vicinity of unprotected equipment. Examples:
- Pipes lacked end caps
- Valves lacked protective caps
- Electric switch boxes were poorly covered
- GRE/FRP tubes were unprotected against falling loads/objects
- Equipment lacked silica gel or this had expired use by dates
This item was also pointed out and described in NCR reports from Master Marine to the shipyard without it had resulted in noteworthy improvements.
- Improvement item: Documents/ certificates: Insufficient and lack of documentation and certificates
- During spot checks of the warehouse, there were discrepancies in the documents from Kongsberg as a package supplier. The PO number was not the same in the documents as on the actual delivery
- A delivery of PSVs was signed out as ”Final”, while only 2 of 8 certificates from the supplier could be produced
- Improvements items: Documentation for the systems: Within certain areas there were insufficient descriptions of how the regulatory requirements are complied with. It was unclear how the company structures the documentation to ensure the best possible user-friendly documentation basis for the operation of the facility.
- ”Fire and Explosion Strategy”, ”Safety Design Philosophy”, ”System Description Firewater” and other documents which specify requirements and philosophies for the safety systems had been prepared for the systems. However, these documents were not used by the engineering office in Singapore or the construction yard in Batam as a basis for the work which is carried out there.
- Several of the documents, referred to above, were, at the time of revision, still under compilation. The documents have some overlapping information and lack some references to illustrate how the requirements are stipulated and how document structure is stipulated.
- To ensure that what is designed and built in Batam is in accordance with the regulatory requirements the company uses a system with change orders in relation to the original Service Jack work scope. Change instruction (CI-003) for changes to the fire water system to meet requirements from the Norwegian Maritime Directorate was verified. This contains a combination of design work and construction work. It was unclear how the company follows up how this CI is implemented and documented.
- The requirements related to emergency lighting on the facility did not appear in the verified documents.
- Several system suppliers are used in the project and the correct information flow at the correct time between the different suppliers and construction sites is regarded as being important to achieving a good end result. However, an ”interface-document” which defines what documentation which must be distributed between the different players and at which time this information must be available had not been established.
- Nonconformity: ESD system: It is not evident from the documentation received that the ESD system is fully in accordance with the regulatory requirements
- The requirements related to the system are found in ”ESD AND F&G Detection Design Base”. System functions which normally are implemented in F&G or other places have been defined. This applies, for instance, to start of the fire pump and start of the emergency generator.
- In accordance with the description of the system, an ESD operator station will be installed in CCR with a back-up station in ECR which consists of a combined ESD/F&G matrix panel with the necessary ESD pressure switches. It does not appear from the description if such a matrix panel will be installed in CCR as well,
- Ignition source control is described as part of the ESD system (cf. section 2.4, subsection 3) where the logic for the system is implemented. At the same time the functional description for F&G (cf. section 3.6, subsection 10) also contains requirements related to ignition source control. The requirements related to independence between the safety systems are not highlighted in the documentation.
- The shut-down levels are described as: APS, ”High” and ”Low”.
- Nonconformity: Fire and gas detection system: According to the design basis and information received, not all aspects have been safeguarded in accordance with the requirements.
- There were no plans to install H2S detectors in the ventilation intake to the living quarters. The reason for this was said to be geographically conditional on the location at the Ekofisk field. It was said that Master Marine will evaluate this in relation to other future use of the facility.
- The design basis does not indicate if a gas detector will be installed in the exterior intake of combustion air to the emergency generator.
- Activation of manual fire alarm only sets off the alarm in CCR (cf. design basis section 3.5) and not a direct alarm in the entire facility.
- All information which Kongsberg needs to complete the design basis is not yet available from all the suppliers. This also applies to information regarding office module to be delivered by ConocoPhillips.
- Improvement items: Fire extinguishing systems: Requirements from different regulatory regimes are used. Therefore it could not be documented that the minimum requirements in the Norwegian Maritime Directorate's regulations were complied with.
- The company generally uses Section 3 of the Framework Regulations and the Norwegian Maritime Directorate's regulations related to fire fighting as basis. At the same time the company uses NORSOK S-001 for example related to fire fighting on the helicopter deck. The company is therefore using requirements from two different regulatory regimes, cf. document ”Technical norms and standards by area and System) as basis.
- Where other requirements than those stipulated in Section 3 the Framework Regulations and the Norwegian Maritime Directorate's regulations, it is not documented that minimum requirements of the Norwegian Maritime Directorate have been complied with. One example in this regards the capacity requirements for fire fighting which are stipulated in the Norwegian Maritime Directorate's regulations relating to helicopter decks.
- As regards documentation for fire fighting systems, we also refer to the report's section 5.5.1.
- Improvement items: Electrical and instrument installation in general: A good, professional execution of the electrical and instrument installation in all phases of installation work should be ensured.
- ”Electrical Installation Standards” to safeguard the requirements related to acceptable standards for example the installation of cables, had been prepared. The document contained many good solutions and the importance of following up that the work is carried out in a professional good manner from the start was emphasized. This applies to, for example, avoiding that cable trays and cable penetrations are overloaded.
- We observed that the installation standards referred to allow for pipes to be installed in the cable trays. It did not appear that there were restrictions in this use which safeguards the requirement in DNV-OS-D201, Ch2 Sec 10 C500, which limits the use of pipes for water, oil and steam in the cable trays.
- During conversations it was revealed that discussions with the construction yard to avoid installing the tubes in switch rooms were taking place. However, it appeared that documentation that the requirement in DNV-OS-D201 Ch2 Sec.2, I201 was fully complied with could not be produced at the time being.