The Petroleum Safety Authority Norway (PSA) has issued Rowan (Valaris) Norway Ltd (Rowan) with a notification of order, having identified serious breaches during an audit of electrical facilities, safety instrumented systems, technical safety and drilling-related systems on Rowan Viking. The audit was conducted between 8 and 12 November 2021.
Rowan holds the Acknowledgement of Compliance (AoC) for Rowan Viking. When the audit was carried out, the facility was on commission to Lundin Energy Norway AS on the Norwegian Continental Shelf.
The objective of the audit was to investigate how Rowan complies with regulatory requirements for electrical facilities, work in and operation of electrical facilities, safety instrumented systems, technical safety and drilling-related systems.
The audit identified 15 regulatory non-conformities. These comprised:
- Non-conformity handling, manning and competence
- Ignition source control
- Overpressure protection
- Passive fire protection
- Emergency power facility
- Emergency lighting
- Risk assessment of evacuation routes
- Work at height and falling object risk
- Electrical facilities and installations
- Electrotechnical system analyses
- Maintenance programme
- Deficient maintenance of BOP
- Work in and operation of electrical facilities
- Risk assessment of health hazards from electromagnetic fields
In addition, we observed two factors that we have chosen to categorise as improvement points. These concerned:
- Training and drills
- Competence and authority
- Follow-up of previous non-conformities
The audit also investigated how Rowan has handled a previous order and some previously identified non-conformities.
We found that Rowan has not addressed the following non-conformities in accordance with the regulations and with their feedback to us:
- Non-conformity concerning electrotechnical system analyses from chapter 5.1.8 of the report pursuant to the audit of electrical facilities and technical safety on Rowan Norway of 25 November 2019.
- Non-conformity concerning work in and operation of electrical facilities from chapter 5.1.9 of the report pursuant to the audit of electrical facilities and technical safety on Rowan Norway of 25 November 2019.
- Non-conformity concerning fire protection from chapter 5.1.1 of the report pursuant to the audit of Rowan Norway/Valaris’s management of emergency preparedness on Rowan Norway of 27 May 2020.
The audit identified serious breaches of the regulations and we have therefore notified Rowan of the following order:
Pursuant to the Framework Regulations, section 69 concerning administrative decisions, Rowan Norway Limited is ordered to:
- Systematically review, map and rectify available staffing and expertise in the company's onshore organisation and on Rowan Viking to ensure that the facility can be operated in accordance with the regulatory requirements during normal operation and in the event of hazard and accident situations. With reference to the Framework Regulations, section 6, first para. concerning the management of health, safety and the environment, section 14 concerning manning and competence and the Activities Regulations, section 25, first para. concerning the use of facilities.
- Ensure that the management system for barrier management and non-conformity handling, together with associated processes, resources and operating organisation, is adhered to in the enterprise. With reference to the Management Regulations, section 5 concerning barriers, section 6, first para. concerning the management of health, safety and the environment, and the Activities Regulations, section 20, second para., item a) concerning the start-up and operation of facilities.
- Ensure that the barriers in chapters 5.1.2-5.1.7 of the report are effective. In addition, a selectivity analysis is to be carried out for protection of the electrical facilities on Rowan Viking, such that successful selective disconnection is documented, with reference to chapter 5.1.11 of the report. With reference to the Framework Regulations, section 3, first para. concerning the application of maritime regulations in the offshore petroleum activities, to the requirements specified for the non-conformities mentioned in the report, the Management Regulations, section 5 concerning barriers and section 16 concerning general requirements for analyses.
- The deadline for complying with the parts 1 and 2 of the order is set at 30 June 2022, and for part 3 is set at the next start-up of operations. We are to be notified when the order has been carried out. Separate notice is to be sent for part 3.