NOPSA: Operators must rigorously apply existing asset integrity management techniques
By Facility Integrity Team, National Offshore Petroleum Safety Authority (NOPSA)
Editor’s note: This article is the third in a series of articles focusing on the critical issue of asset integrity. In previous articles, the International Regulators Forum presented findings from a three-year inspection programme, and the Petroleum Safety Authority Norway and the UK Health and Safety Executive discussed life extension for mobile offshore units. Here, Australia’s National Offshore Petroleum Safety Authority provides an overview of its Facility Integrity National Programme.
Preliminary findings generated from an ongoing national programme of inspection of offshore topsides petroleum process equipment being conducted by the Australian offshore safety regulator suggest there are lessons yet to be learned by the industry in managing asset integrity, but they are not new lessons. The essence of the learning points is that there are well proven management techniques and systems available to operators to achieve effective asset integrity; the operator must be rigorous in implementing its own systems; and this article suggests that, flying in the face of modern human safety behavioural theories, a focus on the fundamental cornerstone of asset integrity – hardware and its maintenance – is crucial.
Background
Australia’s National Offshore Petroleum Safety Authority (NOPSA) is a Commonwealth statutory agency established in 2005 as the occupational health and safety regulator for the Australian offshore petroleum industry. Its vision is that health and safety risks in the industry are properly controlled.
NOPSA’s legislated functions include the promotion of occupational health and safety. It consults with a number of stakeholders, including the Australian Petroleum Production & Exploration Association (APPEA), the peak national body representing Australia’s oil and gas exploration and production industry. As part of NOPSA’s promotion function, in 2006 the agency instituted two national programmes focused on high-priority, industrywide safety issues – lifting operations and facility integrity. NOPSA anticipated several benefits accruing from the programmes:
• A cross-industry review of common offshore technical issues.
• The potential for international benchmarking of Australia’s offshore petroleum industry performance.
• A stimulus for industry, the workforce and the regulator to actively seek learning opportunities and to develop good practices on a collective basis.
• Facilitation and fostering of a structured working relationship between NOPSA and its stakeholders during the early stages of NOPSA’s development.
Similar national programmes have been used successfully in other provinces, notably in the UK sector of the North Sea. The subject of this article, the NOPSA Facility Integrity National Programme, is largely based on the UK’s well-respected HSE KP3 asset integrity programme that commenced in 2004 and was recently completed.
Scope, Development, Execution
Against a background of increasing numbers of hydrocarbon release incidents and cognizant of the fact that this is a key indicator for the potential for a hydrocarbon-related major accident event, NOPSA determined that its Facility Integrity National Programme would aim at the prevention of loss of containment of petroleum fluids that might arise from the failure of offshore production topside structures, process equipment, piping and systems. This would be carried out through the facilitation of operators’ inspection, testing and maintenance arrangements.
The programme was developed to be undertaken in four phases:
• Data acquisition.
• Development of pro-forma inspection tools and guidance documentation.
• Planned inspection execution.
• Analysis and dissemination of findings and joint industry post-programme sustaining projects.
The data acquisition phase involved collating historical hydrocarbon release incident parameters from operators and regulatory agency sources of information with a view to building a database of facility integrity-related uncontrolled hydrocarbon releases. A second aspect to this phase was the introduction of a revised and more detailed reporting format for future use by operators in reporting uncontrolled hydrocarbon releases. This detailed report form was introduced for use on a voluntary basis with the support of APPEA members.
The pro-forma inspection tools and supporting guidance documents were compiled based on the HSE KP3 programme and other industry literature describing asset integrity management systems. The aim was to facilitate an assessment by inspection of the operators’ own inspection, testing and maintenance arrangements for the topside process safety critical elements (SCEs) of their offshore facilities by comparison against selected good practices.
Thus, the pro-forma inspection sheets were developed based on the quality cycle of “plan – do – check – feedback,” where:
• “Plan” encompasses strategy, policy and objectives (including performance standards, organisation, resources, responsibilities and procedures).
• “Do” encompasses implementation and management of change (including how plans and procedures are executed, how responsibilities and resources are allocated, how inspection and maintenance are scheduled and prioritised).
• “Check” encompasses audit and review, performance monitoring and evaluation.
• “Feedback” encompasses corrective actions and improvement loops.
Eight topics are addressed by the inspection sheets:
1. Facility integrity management system – onshore
• Policy and strategic objectives for facility integrity
• Planning, responsibility and authority
• Training and competency
• Deviation, deferrals, monitoring and records
• Audit and review
2. Topsides maintenance system – onshore and offshore
• Maintenance policy
• Communication between onshore support staff and offshore maintenance technicians
• Competence of maintenance technicians and supervisors
• Maintenance of safety critical elements
• Supervision
• Recording of completed maintenance work
• Backlogs
• Deferrals
• Corrective maintenance
• Defined life of temporary repairs
• Measuring the effectiveness of the maintenance system
• Measuring compliance with performance standards
• Measuring the quality of maintenance work
• Verification
• Review of ICP recommendations
• Reporting to senior management on integrity status
• Key indicators for maintenance effectiveness
3. Topsides maintenance system – offshore
• Communication between onshore support staff and offshore maintenance technicians
• Competence of maintenance technicians and supervisors
• Maintenance of safety critical elements
• Supervision
• Recording of completed maintenance work
• Backlogs
• Deferrals
• Corrective maintenance
• Defined life of temporary repairs
• Measuring the effectiveness of the maintenance system
• System test of SCE
• Condition of plant
• Examples of best practice
4. Topsides process integrity
• Process integrity management policy
• Planning of integrity management system
• Integrity competence management
• Monitoring of process systems and procedures
• Audit and review of process plant and management systems
5. Topsides pressure integrity
• Pressure integrity management policy and strategy
• Pressure integrity implementation
• Risk-based inspection (RBI)
• Performance and reporting
6. Topsides corrosion and erosion
• Corrosion management policy and strategy
• Sand erosion management
• Inhibitor injection programme
• Corrosion probes
• Fluid sampling and analysis
• Material selection criteria
• Protective coatings
• Painting programmes
7. Topsides structural integrity
• Code compliance and certification
• Risk-based inspection
• Inspection programmes
• Fit-for-service criteria
• Stewardship of recommended repairs and maintenance
8. Small-bore piping, tubing and flexible hoses
• Strategy and plan
• Field installation
• Performance measurement
To enable easy data analysis and the presentation of findings, assessing and recording of the inspection findings is done by means of the ubiquitous traffic light system whereby:
• Green indicates consistent with good practice.
• Amber indicates partially consistent with good practice.
• Red indicates does not meet good practice (key system elements missing).
The execution phase of the programme is conducted under the auspices of NOPSA’s routine regulatory planned inspections of offshore hydrocarbon producing facilities. There are 12 operators with 71 facilities encompassed by the programme, although a number of these consist of small monopod platforms feeding into a central processing plant and are collectively treated as one facility for the purposes of the programme.
While the option to take regulatory enforcement action against an operator in relation to matters arising from the national programme inspection exists, the primary objective is to facilitate continuous improvement and cross-industry knowledge transfer of good practices in asset integrity management and, ultimately, to improve safety outcomes for personnel offshore.
The execution phase of the programme is now 60% complete. By virtue of interim briefings to industry and in parallel with Phase 3, the Programme has entered Phase 4 – analysis and dissemination of findings.
Hence, although the programme is not yet complete, NOPSA has collected data that indicate that, overall, less than half of the facilities inspected fully meet the good practice expectations in facility integrity management of topside hydrocarbon process related equipment.
There is some correlation between the number of potential and actual uncontrolled hydrocarbon releases on a facility and the quality of the facility integrity management of that facility as measured by the programme. There is no indication that the rising trend in potential and actual uncontrolled hydrocarbon releases is abating.
Nevertheless, good practices have been observed by NOPSA during the programme inspections in, for example, offshore management reporting of performance indicators, onshore-to-offshore communication and staff competence levels.
Equally, the inspections and analysis of uncontrolled hydrocarbon releases have highlighted areas of concern with regard to maintenance backlogs generally and particularly in conjunction with inadequate deferral management, failure to test and maintain SCEs and inadequate SCE performance standards.
Presentations that provide more detailed information on these findings are available on the NOPSA website at www.nopsa.gov.au/programmes.
Conclusion
It is perhaps unsurprising that the NOPSA Facility Integrity National Programme has identified similar issues to those uncovered in other offshore provinces, given the global nature of the industry and, in many ways, the comparable operating environments.
However, given the sophistication of operators’ management systems and the plethora of available asset integrity tools and methodologies, e.g., the International Association of Oil & Gas Producers (OGP) guide to asset integrity, the UK Step Change Asset Integrity Toolkit and the relevant ISO standards, perhaps more surprising is the fact that assets and the safety of offshore personnel are often compromised by a lack of elementary maintenance of the hardware.
This is the perennial challenge of effectively managing asset integrity that may warrant a more fundamental review of the way that facilities are managed.