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Supervision of technical and operational barriers on Valhall

The Norwegian Petroleum Directorate has conducted supervision of BP's safeguarding of technical and operational barriers in the production facility on the Valhall field. The supervisory team has based its work on the regulatory requirements for barriers and has assessed how these are followed up in terms of operation and maintenance of the facility.

The supervision began with an initial meeting at Forus on 19 August 2003 where presentations were given in accordance with our suggestion in the notification of supervision.

The offshore part of the supervision was conducted on Valhall during the period 26-28 August 2003 and consisted of discussions with relevant personnel, inspections of the facility and verifications of systems and documents.

The supervision was carried out according to plan, with an open and good dialogue.


Background for the supervision

The requirements for management and control of barriers have become more stringent in the new HES regulations. This applies both to physical and (technical) and non-physical (operational and organisational) barriers.

In July 2002 we sent a letter to all the operating companies where we referred to the barrier requirements in the new regulations and asked how the operators followed up the technical condition of the physical barriers on the installations.

During the last few years a number of undesirable incidents have occurred which have had a great hazard potential because several of the key operational barriers had failed.

On the basis of this, a number of supervisions are being conducted in 2003 directed at the operators' control and management of the technical and operational barriers on the installations.

During this supervision we have supervised BP's activities related to key barriers on the Valhall installation, such as the work which BP has started in order to map the technical condition on Valhall. This work has not been completed and will be followed up at a later date.

The production facility on Valhall is about 25 years old, and this entails great challenges with regard to maintaining the technical condition while there is also a high level of activity to get things ready for the new flank installations and Valhall IP.

The purpose of the supervision

One of our goals for 2003 is to help the industry gain an overview over, and maintain, a technical condition which allows for safe running of the installations. To this end we supervise that the players are able to manage and control the technical integrity of the physical barriers on the installations and we follow up the players' work to avoid hydrocarbon leaks.

The goal of this activity is therefore to assess how BP safeguards (including identifies the need for, establishes, maintains and further develops) the various barriers that are needed to maintain an acceptable level of safety during operations and maintenance of the production facility on Valhall. Another goal is to assess whether BP's follow-up of the technical and operational barriers complies with the requirements in the new HES regulations. Part of our goal is also to increase the general understanding of the barrier concept and contribute to the concept being used in the widest sense possible, for example for both probability-reducing and consequence-reducing measures.

The result of the supervision

In this supervision we have focused on issues like manning and competence, information and documentation, knowledge of and use of different risk analyses, goals and strategies, planning and implementation of maintenance, and measuring and improvements.

Our main impression from the supervision is that the condition of the technical barriers on the Valhall installation is acceptable, considering the installation's age. No significant shortcomings were identified.

Given that the installation is designed mainly according to previous regulatory requirements, there are deviations according to the current regulatory requirements. These deviations have been identified by BP itself, and we would like to follow up BP's work concerning these deviations.

It is our opinion that BP generally has satisfactory management and control of the maintenance of technical barriers and safety-critical equipment on Valhall. The backlog of program-based maintenance and pending corrective maintenance seems to be at a manageable level with a downward trend.

Concerning the operational barriers, however, some deviations and a potential for improvement were uncovered. This relates mainly to a lack of classification of safety-critical equipment associated with maintenance activities, follow-up of temporary equipment and updating of operating documents.

The coming changes in manning and organisation have not been finally determined, and no assessments were made in this supervision concerning any consequences this might have for the organisational barriers.