The PSA’s specialists conduct a number of supervisory activities with companies in the petroleum sector every year. These can vary in form and content. Join the PSA on a mobile unit over the next few pages to see the course an AoC verification might take.
How is supervision conducted?
PSA personnel usually fly offshore from one of the heliports found along the Norwegian coast, from Sola outside Stavanger to Hammerfest in the far north.
Should the rig be in inshore waters, however, a flight is unnecessary – which is why Svein Horn and his four-strong verification team from the PSA are standing on a quay.
They are watching a small blue-and-white boat laying alongside at the Mongstad base north of Bergen on a dark morning in December.
Their destination is mobile unit Songa Endurance and a two-day verification of its electrical systems, maintenance management, and drilling and well technology.
This rig is a newcomer to Norway, and owner Songa Offshore has applied for the acknowledgement of compliance (AoC) which the unit must have to work on the NCS.
The weather in the Fens Fjord is wet and windy, but the boat makes steady progress towards a blaze of light cutting through the gloom. Two nautical miles out, it slides between the rig’s red-painted support columns.
Equipped with a conference table, a big screen and a system for videoconferencing, the largest meeting room in Songa Endurance’s living quarters is the venue for a kick-off session.
Many Songa employees are involved in the verification, and the room is full of people – including the rig management and key specialists from its drilling, technical and maritime sections.
Also present are the safety delegates and representatives from third-party contractors, along with several staff from the owner’s land organisation.
VIDEO: Join the PSA on a mobile unit to see the course an AoC verification might take.
The platform manager – the person in overall charge and responsible for the safety of both crew and rig – welcomes the PSA team and hands over to Horn.
He provides a brief presentation of the PSA, explains the goal of the verification and presents a proposed agenda for the team’s two-day stay.
A verification always starts with a kick-off meeting of this kind to ensure that everyone is aware of its aims and of the PSA’s role in the work.
Horn also makes it clear that the rig’s safety delegates can have a private meeting with the team and may participate during inspections on board.
The first afternoon is devoted to information-gathering interviews with representatives from the rig management and selected specialists.
Details obtained from these discussions are important for checking how the rig’s technical condition, working environment, systems and procedures comply with the regulations.
This information is collated and assessed along the way to determine what the interviewees have revealed and what that means for the verification.
Time has also been allocated to talk with the safety delegates in order to learn what concerns they have. Such a conversation is a fixed item on the agenda for every PSA verification.
Special adviser Kjell-Gunnar Dørum from the PSA’s process integrity discipline area is ready in overalls and personal protective gear to take a tour of the rig.
A specialist in maintenance management with long experience of auditing mobile units, he is accompanied by the technical managers on the rig and from the land organisation.
Dørum’s first stop is the spare parts store, where he picks a valve on one of the shelves and asks the storekeeper to locate information about it in the maintenance system.
Norway’s petroleum regulations specify a number of maintenance and maintenance management requirements for industry players. The main rule is that a facility must be maintained in such a way that it can perform its intended functions at all stages of its life.
One of Dørum’s aims is to check how the maintenance management system functions, and whether those working on board are sufficiently familiar with it.
Electrical systems, technical safety and dynamic positioning (DP) operations are areas of special concern for Jan Sola Østensen and Svein Harald Glette, also from the PSA’s process integrity area.
That means the chief electrician, the technical manager, the DP operator and the stability manager are all to be found on their list of interviewees.
Horn himself and Gustav W Dunsæd from the drilling and well technology discipline area concentrate on safety-critical equipment and expertise.
The pair have conducted a number of interviews with people involved with drilling, and are now on their way to the top of the rig together with the drilling supervisor.
With a long list of things to look at, they are particularly concerned to see that safety-critical gear is accessible, in good condition, classified and entered in the maintenance system.
Many documents have already been received and much information conveyed verbally. But the tour of the rig will confirm whether this input conforms with reality.
The top of the derrick offers a fine view. Over the horizon, 14 hours of transit time to the west, lies the Troll field where Songa Endurance will drill production wells for Statoil over the next few years.
The PSA team concludes its two hectic days on the rig by holding a final meeting to present its observations and findings to Songa’s representatives.
Back in the PSA’s Stavanger office, the five verifiers collate what they have learnt and write a final report addressed to the responsible supervision coordinator.
The latter, as the person with product responsibility for audits and verifications, has commissioned the team’s work on behalf of the PSA’s management.
Authority to decide whether to issue notification of a possible order if breaches of the regulations have been identified also rests with the supervision coordinator.
In the event of such breaches or if conditions have been found which require improvement, the PSA asks the company to explain how it intends to tackle them. A deadline for responding is also set.
A verification of this kind is only part of the total AoC process, which also embraces information provided by the owner in its application.
Such details include the unit’s technical condition as well as the company’s organisation and safety management system, and are checked by administrative procedures as well as verifications.
The company concerned always receives a copy of the verification report, which is then published on the PSA’s website. When the process has been conducted as part of an AoC application, all related reports are published simultaneously.
The PSA awarded an AoC to Songa for Songa Endurance on 17 December 2015. All the reports related to the process were posted to its website on 8 January 2016.
What is supervision?
The PSA supervises all players in Norway’s petroleum sector, including operators, licensees, contractors and vessel owners. Its responsibility also covers every stage of the industry’s life cycle, from exploration drilling and development to production, cessation and removal.
“Supervision is a broad term, and the activities we pursue in this respect can differ in form and content,” says Ingvill Hagesæther Foss, one of the PSA’s two directors of supervision.
“In addition to audits and verifications, the work covers meetings with companies and acquiring data on accidents and incidents.
“Other activities can include consideration of company development plans, applications for consent to pursue various activities, investigating incidents and so forth.”
But audits/verifications are the most visible part of the PSA’s supervisory function, she says. “That’s when we visit offshore facilities, land plants or construction sites to check compliance with regulatory requirements.
“Our supervisory activities for a development project begin as early as the planning stage, and continue through construction and operation to the removal phase.”
An audit or verification normally falls into two parts, Foss explains. The first of these usually involves a review of documents and meetings with the company management.
“This tells us how the management system is structured and functions, and about the procedures,” she says. “We then go into the field to compare that with the way things work in practice.
“Our supervision is risk-based. Put simply, this means a focus on areas with high risk and big potential hazards, or where the industry or companies have shown weaknesses and performed poorly.”
She cites maintenance management, hydrocarbon leaks and well control as examples of such issues.
Foss notes that it is not unusual for the PSA’s supervisory activities to uncover nonconformities from regulatory requirements.
“Our supervision is system-oriented. This means we view such failures in compliance as a symptom that a company’s management system has not functioned as it should.
“All nonconformities must be corrected, although some are more urgent than others. If the regulatory breach is serious, we can issue an order to the company.
“And we also have the authority to shut down an activity if necessary. But that’s fortunately something we seldom find any need to do.”
“The main priorities for our supervisory work over the coming year are set the previous autumn,” Foss explains. “Our planning and prioritisation draw on information from many sources.”
She emphasises that the PSA is concerned to strike a balance between following up major accident risk and monitoring the working environment in the industry.