WE Report

Audits



Noble Invincible

No person selected

Report No.

6844
Environmental Verification NINV

Type of audit

External Audits
Noble Invincible

Auditee/Customer

Noble Invincible
DNO

Date

2024/09/23

440 days ago

Findings

15
Number of findings

Status

Closed
External Audits


Environmental Verification NINV
Summary

Reference is made to the notification sent 26th August 2024, and updated notification 18th September due delayed start-up of the Falstaff operation, with regards to an Environmental Verification to be conducted at Noble Invincible (NINV). Well Expertise AS (WE) conducted the verification on behalf of DNO Norge AS (DNO).

The verification was carried out to get a better understanding and overview of the processes and work onboard NINV related to barrier-, chemical-, and waste management, with special attention on requirements in the Falstaff Discharge permits given by the Norwegian Environmental Agency (NEA), ref. [1]. The verification was carried out through interviews of relevant personnel and by exploring the rig and doing spot checks of barriers, hose stations, bounding/coaming, drain system, chemical storage areas, and waste stations.

The verification was conducted 23rd-26th of September. No (0) non-conformance, four (4) observations, and 11 improvement suggestions were identified during the verification. The findings were presented and discussed in the closure meeting of the verification. The findings shall be followed up by Noble in IFS.

Findings

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-1: Wrongly sorted waste in the accommodation

    Continuous focus

    16.10.24: Report sent
    04.11.24: Feedback from OIM: Continous focus on rig. Action closed. Noble ref.: RCAL-102862

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-2: Wrongly sorted waste outside Cement Control Room

    Continued focus onboard

    16.10.24: Report sent
    04.11.24: Feedback from OIM: Continous focus on rig. Action closed. Noble ref.: RCAL-102862

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-3: Wrongly sorted waste on Main Deck Starboard

    Continued focus onboard

    16.10.24: Report sent
    04.11.24: Feedback from OIM: Continous focus on rig. Action closed. Noble ref.: RCAL-102862

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-4: Missing information in “Welcome onboard meeting” regarding the environmental sensitivity at Falstaff

    25.09.24: Information included in Welcome onboard meeting

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-1: Digitalization of the Environmental Sensitive Valves (ESV) system

    Good if paper/binder versions are digitalised

    16.10.24: Report sent.
    Week 46: Noble ref.: RCAL-102863
    12.02.25: According to K. Kludzinska, the system is operational in COW, but training sessions will be needed for full digitalization implementation.
    14.03.25: Training with CoW team to be agreed with OIM – extended to 30.05.25. We acknowledge that this topic is followed up and close the finding.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-2: ppm registration on oily water from bilge

    01.11.24 (adjust alarm)
    31.12.24 (implement exact measurements)
    15.01.25 (update measurement program)

    16.10.24: Report sent
    04.11.24 update from rig: – It is decided we will stay with our 15PPM limit and keep sending in analysis ow treated bilge water on a monthly basis. This in accordance with MAPOL 15ppm and HAVTIL 30ppm. Rig does not operate in special protected areas with lower requirement, and to lower the alarm limit does not give any improved quality of the ZDU function. Noble ref.: RCAL-103015

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-3: Incorrect information in NINV “INV-14-0038-001-80” (must be seen in conjunction with IMP-2)

    Update procedure to reflect the right ppm

    16.10.24: Report sent
    04.11.24 Feedback from rig: ZDU & Decanter UNIT in Cantilever is decommissioned and not in use, which this procedure reflects. Noble ref.: RCAL-103014

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-4: Storage of chemicals in sack store that are not included in relevant/current permit

    Remove the chemicals (send to shore)

    16.10.24: Report sent
    22.10.24: Asked for status
    04.11.24: Feedback from rig: The Halliburton chemicals in sack store are now marked belonging to Halliburton and tagged “do not use”. Noble ref.:RCAL102864

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-5: No label on IBC tank at Port hose station

    Put label on

    16.10.24: Report sent
    04.11.24 Feedback from rig: IBC cube properly marked with both content and IMDG signs. Noble ref.:RCAL-103010

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-6: The washing detergent used on NINV is not commonly used on the NCS

    Cleanrig CHP suggested and tried without success. Recommend to try Microsit Polar

    16.10.24: Report sent
    04.11.24: 200 ltr drums of CLEANRIG CHP ordered from the rig on 30/sep, this has still not been received onboard. Noble ref.: RCAL-103011
    21.03.25: All 6 crews have tested and approved CleanRig CHP, and have been using it in replacement to Masawa Max. CLOSED

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-7: Treatment of the left-over grease from the leg levellers

    Secure that this waste is treated properly and labelled correct

    16.10.24: Report sent
    “02.11.2024 MDA: The following received from the Logistic Cordinator – QUOTE: Could not find any labels BUT sourced some in environment STD – I have now ordered and we will see when arriving. I was on board when DNO Environmental audit took place and it is correct I was not able to find any labels – for some reason. Anyway just to point out again – it is dangerous waste BUT not under IMDG/ADR with clarifications. We have always used the hazardous waste numbers they refer to when doing waste declarations.”
    However – we will move forward exactly same way as always BUT this time with a label on drums and NOT hand written. UNQUOTE – Labels ordered on PR 1127629.”
    Noble ref.: RCAL-103016

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-8: Empty chemical can was not empty

    Secure that this type of waste is handled correctly

    16.10.24: Report sent
    22.10.24: Asked for status
    04.11.24: The can has been emptied. Noble ref.:102865

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-9: Shaker screens, waste handling and screen washer

    Improve tubings on screen washer and secure proper handling of the waste

    16.10.24: Report sent
    11.11.24: The screen washer, has, as described, never been effective at cleaning screens. It has been checked, and does function as designed, which is poor. Research into alternative/ improved screen washers has been done, but to date with no positive outcome. Even with a fully operative screen wash system, consideration must be given to manual handling and the transport of the screens to any cleaning unit. Again, after study, this has not been resolved. Screens would always have to be prewashed prior to removal from shaker and transfer to a cleaning unit. If this was not done, then the weight of the screen and slip hazard from spills would be a credible risk to the operators. To counter HSE issues when cleaning screens (aerosols of water/OBM) with power washer, then battery powered clean air filter units are always used. Screens are power washed prior to scrapping. Noble ref. RCAL-103017.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-10: Labelling

    Several tubings missed or had torn labels – NINV should secure new labels

    16.10.24: Report sent
    11.11.24: Noble ref.: RCAL-103018
    19.12.25: This is an ongoing job. New labels installed when weather and circumstances permit it. CLOSED by NINV

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-11: Cleaning of the main deck

    Very dirty and should be cleaned – mostly due to the working environment

    16.10.24: Report sent
    22.10.24: Asked for status
    04.11.24: Main deck has been cleaned, and the deck crew is dedicated to its ongoing cleanliness. Noble ref.: RCAL-102866



Additional Documentation

PL1086-DNO-S-RA-0018_Environmental-Verification-NINV-September-2024_rev.-02-signed.pdf


PL1086-DNO-S-RA-0018_Environmental-Verification-NINV-September-2024_rev.-02-signed.pdf




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Noble Invincible

No person selected

Report No.

6844
Environmental Verification NINV

Type of audit

External Audits
Noble Invincible

Auditee/Customer

Noble Invincible
DNO

Date

2024/09/23

440 days ago

Findings

15
Number of findings

Status

Closed
External Audits


Environmental Verification NINV
Summary

Reference is made to the notification sent 26th August 2024, and updated notification 18th September due delayed start-up of the Falstaff operation, with regards to an Environmental Verification to be conducted at Noble Invincible (NINV). Well Expertise AS (WE) conducted the verification on behalf of DNO Norge AS (DNO).

The verification was carried out to get a better understanding and overview of the processes and work onboard NINV related to barrier-, chemical-, and waste management, with special attention on requirements in the Falstaff Discharge permits given by the Norwegian Environmental Agency (NEA), ref. [1]. The verification was carried out through interviews of relevant personnel and by exploring the rig and doing spot checks of barriers, hose stations, bounding/coaming, drain system, chemical storage areas, and waste stations.

The verification was conducted 23rd-26th of September. No (0) non-conformance, four (4) observations, and 11 improvement suggestions were identified during the verification. The findings were presented and discussed in the closure meeting of the verification. The findings shall be followed up by Noble in IFS.

Findings

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-1: Wrongly sorted waste in the accommodation

    Continuous focus

    16.10.24: Report sent
    04.11.24: Feedback from OIM: Continous focus on rig. Action closed. Noble ref.: RCAL-102862

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-2: Wrongly sorted waste outside Cement Control Room

    Continued focus onboard

    16.10.24: Report sent
    04.11.24: Feedback from OIM: Continous focus on rig. Action closed. Noble ref.: RCAL-102862

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-3: Wrongly sorted waste on Main Deck Starboard

    Continued focus onboard

    16.10.24: Report sent
    04.11.24: Feedback from OIM: Continous focus on rig. Action closed. Noble ref.: RCAL-102862

  • Observation

    Closed


    Closed


    Deadline was:

    OBS-4: Missing information in “Welcome onboard meeting” regarding the environmental sensitivity at Falstaff

    25.09.24: Information included in Welcome onboard meeting

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-1: Digitalization of the Environmental Sensitive Valves (ESV) system

    Good if paper/binder versions are digitalised

    16.10.24: Report sent.
    Week 46: Noble ref.: RCAL-102863
    12.02.25: According to K. Kludzinska, the system is operational in COW, but training sessions will be needed for full digitalization implementation.
    14.03.25: Training with CoW team to be agreed with OIM – extended to 30.05.25. We acknowledge that this topic is followed up and close the finding.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-2: ppm registration on oily water from bilge

    01.11.24 (adjust alarm)
    31.12.24 (implement exact measurements)
    15.01.25 (update measurement program)

    16.10.24: Report sent
    04.11.24 update from rig: – It is decided we will stay with our 15PPM limit and keep sending in analysis ow treated bilge water on a monthly basis. This in accordance with MAPOL 15ppm and HAVTIL 30ppm. Rig does not operate in special protected areas with lower requirement, and to lower the alarm limit does not give any improved quality of the ZDU function. Noble ref.: RCAL-103015

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-3: Incorrect information in NINV “INV-14-0038-001-80” (must be seen in conjunction with IMP-2)

    Update procedure to reflect the right ppm

    16.10.24: Report sent
    04.11.24 Feedback from rig: ZDU & Decanter UNIT in Cantilever is decommissioned and not in use, which this procedure reflects. Noble ref.: RCAL-103014

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-4: Storage of chemicals in sack store that are not included in relevant/current permit

    Remove the chemicals (send to shore)

    16.10.24: Report sent
    22.10.24: Asked for status
    04.11.24: Feedback from rig: The Halliburton chemicals in sack store are now marked belonging to Halliburton and tagged “do not use”. Noble ref.:RCAL102864

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-5: No label on IBC tank at Port hose station

    Put label on

    16.10.24: Report sent
    04.11.24 Feedback from rig: IBC cube properly marked with both content and IMDG signs. Noble ref.:RCAL-103010

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-6: The washing detergent used on NINV is not commonly used on the NCS

    Cleanrig CHP suggested and tried without success. Recommend to try Microsit Polar

    16.10.24: Report sent
    04.11.24: 200 ltr drums of CLEANRIG CHP ordered from the rig on 30/sep, this has still not been received onboard. Noble ref.: RCAL-103011
    21.03.25: All 6 crews have tested and approved CleanRig CHP, and have been using it in replacement to Masawa Max. CLOSED

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-7: Treatment of the left-over grease from the leg levellers

    Secure that this waste is treated properly and labelled correct

    16.10.24: Report sent
    “02.11.2024 MDA: The following received from the Logistic Cordinator – QUOTE: Could not find any labels BUT sourced some in environment STD – I have now ordered and we will see when arriving. I was on board when DNO Environmental audit took place and it is correct I was not able to find any labels – for some reason. Anyway just to point out again – it is dangerous waste BUT not under IMDG/ADR with clarifications. We have always used the hazardous waste numbers they refer to when doing waste declarations.”
    However – we will move forward exactly same way as always BUT this time with a label on drums and NOT hand written. UNQUOTE – Labels ordered on PR 1127629.”
    Noble ref.: RCAL-103016

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-8: Empty chemical can was not empty

    Secure that this type of waste is handled correctly

    16.10.24: Report sent
    22.10.24: Asked for status
    04.11.24: The can has been emptied. Noble ref.:102865

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-9: Shaker screens, waste handling and screen washer

    Improve tubings on screen washer and secure proper handling of the waste

    16.10.24: Report sent
    11.11.24: The screen washer, has, as described, never been effective at cleaning screens. It has been checked, and does function as designed, which is poor. Research into alternative/ improved screen washers has been done, but to date with no positive outcome. Even with a fully operative screen wash system, consideration must be given to manual handling and the transport of the screens to any cleaning unit. Again, after study, this has not been resolved. Screens would always have to be prewashed prior to removal from shaker and transfer to a cleaning unit. If this was not done, then the weight of the screen and slip hazard from spills would be a credible risk to the operators. To counter HSE issues when cleaning screens (aerosols of water/OBM) with power washer, then battery powered clean air filter units are always used. Screens are power washed prior to scrapping. Noble ref. RCAL-103017.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-10: Labelling

    Several tubings missed or had torn labels – NINV should secure new labels

    16.10.24: Report sent
    11.11.24: Noble ref.: RCAL-103018
    19.12.25: This is an ongoing job. New labels installed when weather and circumstances permit it. CLOSED by NINV

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-11: Cleaning of the main deck

    Very dirty and should be cleaned – mostly due to the working environment

    16.10.24: Report sent
    22.10.24: Asked for status
    04.11.24: Main deck has been cleaned, and the deck crew is dedicated to its ongoing cleanliness. Noble ref.: RCAL-102866



Additional Documentation

PL1086-DNO-S-RA-0018_Environmental-Verification-NINV-September-2024_rev.-02-signed.pdf


PL1086-DNO-S-RA-0018_Environmental-Verification-NINV-September-2024_rev.-02-signed.pdf



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