Notice of the order was given on 28 October 2020. The order was issued on 17 November 2020.
The audit was carried out on 9-10 September 2020.
Draugen lies in the Norwegian Sea. Its licensees are Okea (operator), Petoro and Neptune Energy.
Norske Shell (Shell) was the operator for Draugen until December 2018, when this responsibility was taken over by Okea.
The field has been developed with a concrete gravity base structure supporting an integrated topsides, and features both platform and subsea wells. It came on stream in 1993.
Draugen’s original producing life was 30 years, and Okea currently has consent to stay on stream until 2024. The operator is expected to apply for an extension to the field’s producing life.
Oil is produced on Draugen from two formations. These are about 1 600 metres deep and homogenous, with good reservoir properties. The field is produced with the aid of pressure support through water injection and the use of gas lift in certain wells.
The purpose of the audit was to assess how Okea ensures compliance with official regulations and its own internal requirements related to major accident risk and hydrocarbon leaks.
That includes processes for risk management, well maintenance and following up the integrity of the Draugen wells.
The PSA wanted to verify the company’s follow-up of the technical condition of the platform and subsea wells on Draugen, with monitoring and maintenance of well integrity, and that planned well maintenance is being carried out in a robust manner.
Draugen has a number of wells with deficient or weakened barriers today, without plans having been presented for repairing or restoring them. Several have long had weaknesses without Okea conducting an internal verification of well integrity status since taking over as operator.
An internal assessment of the wells at the transfer from Shell was carried out by Okea personnel who did not participate in the audit. Neither Okea nor other licensees in the production licence have subsequently considered an internal or independent review and verification of well integrity status, despite the field’s long producing life and associated lengthy production and injection history.
When the PSA audited Okea’s maintenance management on Draugen in 2019, it found that the company faced challenges in establishing and updating its own management system with associated processes and procedures.
The latest audit found verification and documentation of integrity status to be lacking for a number of production and injection wells. This relates to some extent to the lack of independence between roles in production optimisation and technical responsibility for well integrity.
These findings are serious, and the PSA’s observations show that Okea has not accepted sufficient responsibility for following up and managing well integrity in the operational phase, and that the company has largely based itself on continued operation without an updated quality assurance and verification of the technical condition of the wells.
Nonconformities and improvement points
The audit identified three breaches of the regulations and four conditions categorised as improvement points.
- deficiencies in barriers in a number of operational wells
- lack of verification of well barriers
- deficiencies in updated documentation of well integrity status.
Improvement points are
- inadequate independence between roles and associated expertise requirements for maintaining the function of the roles related to well integrity
- inadequate documentation of the use of recognised norms
- inadequate setting of performance requirements for well integrity
- inadequate follow-up of the maintenance programme.
Notice of an order
The audit of Okea’s follow-up of well integrity status on Draugen identified serious breaches of the regulations, and the company has now been given the following order.
Pursuant to section 69 of the framework regulations on administrative decisions, see sections 6, 21 and 5 of the management regulations on management of health, safety and the environment, on follow-up and on barriers respectively, section 48 of the facilities regulations on well barriers, and section 85 of the activities regulations on well barriers, Okea is ordered to review, quality-assure and update the well integrity status of the 22 wells on the Draugen field. See sections 5.1.1, 5.1.2 and 5.1.3 of the audit report.
To ensure that well integrity is maintained, the company is ordered to implement measures for ensuring that non-functioning or weakened well barriers and barrier elements are known, so that measures can be initiated to correct or compensate for missing or weakened well barriers. See sections 5.1.1 and 5.1.2 of the audit report.
A scheduled plan for the way this work is to be implemented and followed up must be submitted to the PSA by 1 December 2020.
The deadline for complying with the order is set at 1 March 2021 The PSA is to be notified when the order have been carried out.