The audit was conducted from 21 to 24 October 2019.
The PSA issued Rowan Norway with an acknowledgement of compliance (AoC) in 2012. This facility returned to the Norwegian continental shelf (NCS) in the summer of 2019 after a nine-month drilling assignment off Turkey. Before then, it had been laid up at Dundee in the UK for a couple of years.
During the audit, Rowan Norway was working for ConocoPhillips on the Tor field. See: Consent to use Rowan Norway at Tor.
The purpose of the audit was to check that operation of electrical installations and the requirement for a responsible supervisor of these facilities were implemented in accordance with the regulations. Checks were also made that the technical safety systems were being operated and maintained in compliance with the requirements.
The audit revealed that a good many technical conditions on board were not being adequately followed up. Where electrical equipment in Ex areas was concerned, inadequate maintenance had resulted in a failure to maintain the Ex integrity of explosion-proof equipment. As a result of this finding, a meeting between Rowan and the PSA took place on 28 October 2019. It emerged there that Rowan had initiated measures in the wake of the audit with additional manning to ensure that the Ex integrity of the equipment was dealt with before drilling activity started.
A number of other nonconformities were also identified during the audit. In the PSA’s view, several of these can be related to an inadequate system for following up the various barrier elements. The company maintained that activating three projects in a relatively short space of time had been labour-intensive. However, it has recently increased capacity to strengthen follow-up.
Nonconformities and improvement points
The PSA has identified regulatory breaches in the following areas:
- internal follow-up
- barrier management
- ignition source control
- fire doors and passive protection
- lighting in the emergency hospital
- technical conditions with electrical installations
- electrotechnical system analyses
- work with and operation of electrical installations
- responsible supervisor for the electrical installations.
In addition, an improvement point was identified which related to function testing of the emergency shutdown system and technical operating documentation.
Follow-up of earlier nonconformities
During the audit, the PSA also looked at the way Rowan has dealt with nonconformities identified by earlier audits of the company
This found that the following nonconformities from a 2012 audit of Rowan Norway had not been corrected in line with Rowan’s feedback to the PSA.
- Nonconformity concerning ignition source control
A gas detector had still not been installed in the driller’s cabin. The PSA was informed in earlier feedback that this would be done by 20 December 2013. During verification of the cabin, it was also observed that unprotected electrical equipment had not been removed as reported in earlier feedback.
- Nonconformity concerning the cement unit
It emerged from conversations and verification that a flame detector was installed in the machinery room for the cement unit, but not a smoke detector. It was reported that the latter had erroneously been positioned in the cement unit room.
The company had earlier informed the PSA that an improvement point on overpressure in the living quarters would be dealt with by 1 March 2013. A visual metering instrument was installed in the radio room, but not connected to the alarm system for continuous monitoring.
What happens now?
The PSA gave Rowan a notification of order on 26 November 2019.
Pursuant to that notice, the following order has now been issued to Rowan:
Pursuant to section 69 of the framework regulations on administrative decisions, see sections 5, 6, 21 and 22 of the management regulations on barriers, management of health, safety and the environment, follow-up, and handling of nonconformities respectively, we order you to
- review the company’s systems for barrier follow-up. Corrective measures must be initiated to ensure that the follow-up helps to identify and correct technical, operational or organisational weaknesses, faults or deficiencies in safety-critical barrier elements
- review the company’s system for handling nonconformities so that these are corrected, their causes identified and corrective measures initiated to prevent their recurrence,
See chapter 5.1.1 of the report on internal follow-up.
A scheduled plan must be submitted by 20 December 2019 which ensures that the company complies with the order. The deadline for compliance with the order is 1 April 2020. We must be informed when the order has been complied with.