The audit of compliance with requirements in the Major Accident Regulations was carried out in cooperation with the Norwegian Climate and Pollution Agency (Klif). Klif has submitted its own report from the audit.
The audit activity was conducted with a basis in the Temporary Regulations relating to safety and working environment for certain petroleum facilities on land and associated pipeline systems, as well as the Major Accident Regulations. The activity was also linked to the PSA’s main priorities for 2010, including ”management and major accident risk”, which in turn includes learning from serious incidents and how Statoil manages ”technical and operational barriers” to reduce major accidents.
The objective of the activities was to verify that Hammerfest LNG safeguards the requirements in the Major Accident Regulations, verify that selected safety-critical barriers are managed in a comprehensive and consistent manner, as well as to verify that management is involved in and contributes to systematic work aimed at learning from and preventing incidents.
Several improvement items were identified, particularly in relation to learning from external incidents as well as resources and competence in barrier control.
The audit did not reveal any nonconformities.
Improvement items in relation to the Major Accident Regulations
There is a large backlog of maintenance of safety-critical equipment.
It emerged during interviews and presentations that there are a large number of outstanding maintenance tasks.
A number of conversations have confirmed the significant backlog as regards maintenance of safety-critical equipment, a fact which places Snøhvit near the bottom of the benchmarking in this area in Statoil.
We noted that that efforts to improve this have been intensified, so that Hammerfest LNG shows slow improvement compared with other units in the company. However, much remains to be done.
There is also a substantial backlog in the program-based maintenance, but the trend here appears somewhat better.
Improvement items linked to learning from incidents
Learning from incidents
Learning and implementation of measures following the company’s own incidents (at Hammerfest LNG) appears to be good. As regards other relevant incidents, both international and in Norway, implementation of measures appears haphazard.
Based on interviews, the flow of information mainly appears to take place through technical networks, and implementation of potential measures thus depends on personal initiative. This appears to be the general rule at Statoil’s land facilities. The PSA believes much can be learned from serious incidents outside one’s own facilities and we urge the company to adopt a more systematic and managed review of selected incidents.
Improvement item linked to safety-critical elements (barriers)
Knowledge of the facility’s risk areas and understanding the importance of barriers in reducing risk can be improved
There appears to be deficient training and understanding for how the facility is divided into different hazard zones, how components and equipment contribute to the risk picture, what requirements are set for barriers and the impact that the most important barriers have on reducing risk.
From interviews held we learned that personnel had varying understanding for how the different components and parts of the facility contributed to the overall risk picture. Appendix F in the risk analysis (TRA) provides a good overview of this, but few people were aware of or used this document.
Similarly, we asked questions about the requirements stipulated in the regulations and in Statoil’s governing documents for important barriers intended to prevent or limit a fire or explosion. Reference was made to TR 2237 (Performance Standards), and few people were aware of or used this document.
It is important that technical and operational barriers are safeguarded in a comprehensive and consistent manner so that the risk of major accidents is reduced as far as possible, and that knowledge on how to safeguard and improve technical and operational barriers is further developed.
Within those areas where individuals had a direct responsibility, our impression was that competence was good.
The PSA is aware that TR 2237 was not used in the design of Hammerfest LNG.
Internal follow-up of the work linked with TTS can be improved.
There seemed to be some lack of interest in and understanding of the importance of the TTS work in order to achieve good control over the condition of barriers, and the significance this work has for improving safety.
Questions regarding some of the important findings in the TTS report were posed during the interviews. The responses we received were somewhat evasive with regard to knowledge of the report, as well as interest in and responsibility for the report. Several people mentioned that the report had just recently been received, and that they were waiting for management to process the report.
The topics in the report that we asked questions about were:
All of these factors are important elements in barrier control.
In addition, an important part of the basis for the performance requirements the TTS review is based on are described in TR 2237. It should be possible to use this more effectively to improve barrier quality.