8.07 Preventing disconnect of wellhead connector.

The current system installed (Covers over functions) to prevent an unintentional disconnect of the WH connector during drilling by human or technical fault is not acceptable and not according to PSA,Norsok D-001 and Contract.

Odfjell to ensure that it is not possible to unlock the BOP due to a human error or system fault. A physical locking device on the HPU panel handles during drilling operation can be one solution to this issue.

From Synergi 229320:
For the annual TBAMI capacity test jobs for Fire pumps, the test procedure is stated in the
Performance Standard document attached to the job.
The performance standard PS-SCE-FG2-03-T for capacity test of fire pumps states the
following procedure to verify the capacity: TBAMI test PS-SCE-FG2-03-T:
———————————————————–
” During this test 2 pumps needs to be running simultaneously.
Open two fire monitors in moon pool, release deluge on drill floor and open adjacent two
fire hydrants at the same time.
Check system pressure (min.7 Bar) in one of the hydrants at Heli-deck. ”
———————————————————–
The test is considered “passed” if the measured pressure is minimum 7 Bar, and the
corresponding “Route Actions” in the job are then set to “passed” or “failed” depending of
result.
I hope this will clarify how the test actually is done and documented.
The tests were all set in “passed” during last test (and previous as well.

RBV: 31.1.2023:  Finding derated to Cat B.  Awaiting MOC and plan of action for WH Connector to be secured ​​​

RBV:  30.01.23: OD (Bjarte Fadnes) to require this Finding to be derated from Cat A to Cat B prior to  conducting an MOC to be able to  upgrade the system.  However,now (ref. mail from OMV DSV regarding this matter) it appears that the rig has solved the problem on their own and that they are in the process of installing an acceptable solution.  Has to be sorted out + documentation of selected solution and confirmation of installed system is outstanding
 
RBV: 27.01.2023:  A safety device to be installed to prevent unintended disconnect of WH connector during normal operations

RBV: 27.01.2023: Provided “evidence” explaining why a locking/safety device will NOT be installed on DSY (which can prevent the WH connector to accidentally disconnect (either by human or technical errors) is not found acceptable

RBV: 26.01.2023:  Awaiting:

1. MOC/risk assessment, addressing why a safety device, which will prevent the WH connector from being disconnected inadvertently, either by human errors or technical faults, will not be installed on DSY and that the current arrangement is considered to fulfill all functional requirements. 
 
2. Also we need a statement from both the OEM and DNV stating that a safety device, as described by OMV, is not deemed necessary, or that it is considered to increase the risk of malfunction of the actual functions

RBV:24.01.2023: OD to revert with a MOC/Risk Assessment justifying why a locking/securing device, which can prevent the WH Connector from being activated i.e. go to disconnect mode as a result of either human or technical/system error, will not be installed on DSY

​SV-24-01.2023 (Comments in Meeting): OD states that they will not modify a DNV approved design/system. OD has however not forwarded a risk assessment with relevant arguments for not performing the action. OD will Forward the argu​ments.

8.13 Pressure reading on manual choke valves.

The Pressure gauges installed on the Choke Manifold has a scale which makes them unsuitable in case of circulating out a kick in well control situation and by that not meeting requirements.These gauges will have to be used, if using the manual chokes during a well control situation, and with a scale spanning from 0-20000 psi they are considered more or less useless.These types of gauges are not sufficient to be able to identify low pressure that is the most common scenario when a kick is to be circulated out.

A system that can detect and show low pressures more accurately to be installed close to the manual chokes.

Synergi 229339
Approved and DNV certifies as is. Gauge measures steps of 25 psi (1,72 bar). It is meant as a backup system in the event power and HPU fails. Feedback from drilling personnel is that it works fine when handling kick using this gauge during choke drills. Also, no proper solution available.

RBV: 31.1.2023: Documentation still pending.

RBV:27.1.2023: OD to present action plan for upgrade of current gauges.

CSV-17-01.2023 (Comments in Meeting): OD are waiting for DNV approval -will not be in place before commencement. OD to forward the plan/ time estimate for how this will be solved

8.01 Recording and documentation of Emergency Training.

A spot-check of the Emergency Drill and Training Program for a specific week (46) revealed a deviation between scheduled/planned Drills and Exercises and actual performed Drills and Exercises.14 (1 Drill & 13 Exercises) vs. 8 (1 Drill & 8 Exercises). This non conformity was not flagged or recorded in Synergy.

DSY has established separate systems for planning / scheduling of Drills/Training (Drill Matrix) of Emergency Team and recording of actual executed Drills/Exercises (Rig Manager).There is no direct communication between these systems, hence there is no flags/alarms warning the responsible that Drills/Exercises are overdue or not executed or reported as done.

The nonconformity is not actively acted on since it requires an active investigation by the responsible user, hence it is not recorded as a nonconformity in Synergy where it can be acted on.

The identified discrepancy between planned Drills/Exercises and Performed (recorded) Drills/Exercises may indicate a weakened or impaired organizational barrier with regards to emergency preparedness.

OD must document that all emergency training is performed and recorded as planned / intended to ensure that barriers related to emergency preparedness are maintained. Any discrepancies between planned Drills/Training and Actual performed Drills/Training must be treated/recorded as a nonconformity in e.g. Synergy

Also, OD should evaluate and or improve current system for planning and recording of drills/exercises and routines for using these tools to prevent recurrence of these nonconformities.

SS- 17.07.23 Spot checks performed as part of the Vår Energi Rig Intake process and found OK.

SS – 20.02.23 Approved in the OD system

RBV-24.01.2023 Based on the provided information we will change the criticality from Cat A to Cat C with a new Due date for final closure of Finding 8.01 set to 31st of March.The OMV HSE Coach will follow up to confirm that the implemented measures works

19.01.2023 JKAA.As described, discrepancy between the drill matrix and the actual logged drills/training were observed. Routines for weekly follow up by SSL is established to ensure that all exercises/training tasks has been met and to ensure quality of logging including the evaluation and corrective actions in case of Performance standar not beeing met.Routines for exercise follow up by SSL is established in revised CMS ” Verifikasjon og logging av Øvelser i Rig Manager CMS 82051.And a new Excel file has been made to to cross check training matrix against drills reported in rig manager.This will make it possible to pinpoint every crewmembers training records for the last 2.5 years

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.02 Measuring and documentation of performance standards to emergency preparedness.

Performance standards for emergency preparedness exercises are not sufficiently measured and documented after exercises. OD use Rig Manager to report and document emergency preparedness exercises. The report templates in the Rig manager are set up for each DSHA scenario that is defined in the Emergency Preparedness Analysis(EPA) for DSY. Each scenario is pre-set with the related performance standards for each step that apply to the exercise. Spot checks in Rig Manager showed that there were several exercise reports where the performance standards were not sufficiently measured and documented.

OD must document that the performance requirements for emergency preparedness are measured and documented to verify that the performance requirements are met.

SS- 17.07.23 Spot checks performed as part of the Vår Energi Rig Intake process and found OK.

SS – 20.02.23 Approved in the OD system

RBV: 24.01.2023 Based on the provided information we will change the criticality from Cat A to Cat C with a new Due date for final closure of Finding 8.01 set to 31st of March. The OMV HSE Coach will follow up to confirm that the implemented measures works

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.03 Handling of Nonconformities

Handling of nonconformities is not performed according to governing and internal requirements. During interviews it became clear that findings from previous rig intake for OMV/PGNiG/Neptune had not been followed up and closed out. OD could not document that:
-nonconformities had been corrected, or recorded in Synergi,
-necessary compensating measures were implemented,
-evaluations for preventing recurrence,

Spot checks were made of following nonconformities:
Procedures related to well control Use of Synergy Systematic mapping of non-ex ignition sources Deviating drills and training Spares for WCS Odfjell had not recorded the deviation/ dispensation in Synergi and could not present a risk assessment related to i.e., emergency release, move off from well centre, use of mooring lines for emergency towing. (Ref. finding 8.40)

The above-mentioned nonconformities are solely spot-checks and Odfjell needs to do a complete review of the current status, record outstanding findings in appropriate system for handling of nonconformities, typically Synergi, or similar.

Odfjell must review their processes regarding.
-recording of nonconformities-implementing mitigating actions when a nonconformity has been identified
-implement measures for preventing the nonconformity to reoccurs

The measures shall be followed up and the effects evaluated.

ÅKP 17.07.23 ref. synergi 229328 All actions are closed related to the follow up.
RBV-27.1.2023:Thank you John Anders we confirm that we will derate the Finding 8.03 and 8.19 from Cat A to Cat C based on provided documentation and action plan described in Synergi Cases 229328 and 229311.Follow up and evaluation of effectiveness of implemented actions should be done on a frequent basis during operations commencing with the Eirik operations i.e. this should be a topic for the regular joint HSE status meetings.

RBV -24.01.2023:Finding 8.03 together with Findings 8.04 and 8.19 will be declassified from Cat A to a Cat C findings upon recieving an action plan addressing what OD will do to improve the process of identifying, recording and handling og Non-conformities, and also to ensure proper identification, reporting and reinstating impaired Technical, Operational & Organizational barriers

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation,-the case regarding CC56 should be reported/recorded in Synergi.

8.04 Barrier Management

The drilling contractor demonstrated lack of awareness of which barriers were established and which function they were intended to fulfil. Reporting of failed or weakened barriers were not performed according to routines, hence the actual barrier status was not correctly reflected. Examples that substantiate the finding: TBAMI (Technical Barrier Against Major Incidents) test of Rig Savers had been recorded as “failed” in the maintenance system IFS. The crew had followed the steps in the job description and the Rig saver had failed to close when the emergency stop button was activated. All 12 rig savers had the same problem and all 12 were reported as “failed” in the maintenance system, the 18th of November 2022. Odfjell could not document that a risk assessment had been performed, or that a Synergi Case had been recorded. The “Barrier dashboard reflected an impaired barrier regarding ignition source control. The alarm delay-time (max, 30s) were adjusted above requirement for several differential pressure transmitters. Some transmitters had alarm delay for 120s. Odfjell could not present a TBAMI job for calibration and testing of the integrity for rooms classified as “safe by ventilation”. Odfjell had not recorded the deviation/ dispensation (DNV class CC 56-wire damage) in Synergi and could not present a risk assessment related to i.e., emergency release, move off from well center, use of mooring lines for emergency towing. The weakened condition of the mooring lines was not treated as an impaired barrier with corresponding mitigating measures. Performance standards for emergency preparedness exercises are not sufficient measured and documented after exercises. Training of emergency teams are not sufficiently recorded and followed up in Rig Manager i.e. there are no measures to explain/elaborate on deviation between planned/scheduled and actually executed Exercises/Drills. Ad. Non-conformances/Deviations identified for L-4 procedures item 4, 5, 6, 8 under Chapter 7.3. Several of these incidents were found closed in Synergi, however several were still found incorrected, and some with wrong/erroneous content related to the procedure. Flame detectors in moonpool were inhibited without recordings in the log (on bridge). Maintenance related to Barrier Elements, Firewater Pumps

Necessary measures to remedy or compensate for missing or impaired barriers could not be documented. Testing and reporting of associated performance requirements is a prerequisite to be able to establish effective barrier management.

Odfjell must ensure that regulatory requirements are met for the barrier management system.

SS – 20.02.23 Closed by OD. Comment a.) in the report regarding “failed” testing of Rigsavers:
The jobs was put in “failed” just to be on the safe side because the instruction seemed to
be incorrect regarding use of Emergency stop. A corrective job was created to follow up
this with engine vendor (Bergen Engines) WO26005963.
Vendor has now confirmed our job description was incorrect and given us the correct
procedure for testing.
Made IFS MMS CASE 5003682 for having this corrected.

RBV: 27.01.2023: Based on provided documentation Finding will be derated from Cat A to Cat C. The effect of the suggested Action plan to be monitored and followed up during operations.

CSV-24-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, Overall OD plan after the PSA audit on DSA.

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.05 GAP analyses new requirements.

OD could at the time of the verification on DSY 15, 16 & 19.12 not present a complete Gap analysis/overview of
compliance with regards to changes in (also new) regulations applicable for DSY. With regards to Well Control Equipment a GAP analyses had been performed against DNV-E-101 and API 53. OD had no plans to map against other relevant standards e.g. Norsok D-010, API 16D etc.

Odfjell to gap all relevant standards to ensure that they have control over new requirements. Risk assessed or implemented important differences since the requirements at design date is required. Odfjell shall have control if any important requirements have been added that could be relevant for Yantai.

RBV: 31.1.2023: OD to present an overview of status of compliance wrt to regulations applicable for DSY, ref. Adept To be followed up

ÅKP: 01.08.2023 Continous process that are managed. Case closed in synergi.

8.06 Working Environment – Shaker/Mud process area

International SOS have performed a verification of chemical exposure in Mud treatment areas on board in October 2022. The report could not be presented for the verification team. As soon as the report is finished a copy should be forwarded to OMV

OD to inform OMV any deviations are revealed.

SS – 20.02.23 Closed in the OD system. ISOS report received.

RBV: 31.1.2023: OD to present latest ISOS report and an action plan for further follow up of Working Environment – Shaker/Mud process area

8.09 ROV unlock of WH connector.

In an emergency situation where the ROV is required for unlocking of the WC connector by a higher pressure than provided by the main system from the rig (i.e., in case of main system failure) may not work due to the design of the actual H4 Wellhead Connector. It should be possible to isolate the primary or secondary chambers by ROV to ensure that one of the circuits can be used if a leak in one of the unlock chambers.

Replumb the connector in a way that primary and secondary unlock chambers can be isolated by a ROV valve to be able to isolate a leaking circuit and still be able to use the ROV on the other circuit.

SS – 31.03.23 Closed. Un-latch of WH connector from ROV will be the third operation (Active pod, Backup pod, ROV). It Is up to the operator to decide and Inform Odfjell If a higher unlock pressure Is required. Then It Is possible to upgrade the system with two ROV valves at operator cost. However, a more complex system will have more leak points and fail sources. Wellesley and DNO considered this finding closed.

SS – 20.02.23 Closed in the OD system

STIM 04.01.23 Un-latch of wellhead connector from ROV will be 3rd operation:

1 Activ POD
2 Backup POD3 ROV

If higher pressure than main system can deliver is required it is likely that both primary and secondary will be needed to un-latch wellhead connector. It is not possible to split primary and secondary and get full functionality with one ROV valve, two ROV valves will be needed. A more complex system will have more leak point and fail sources. Current system is according to applicable standards

30.1.2023

RBV: 31.2023: Further dialog with OD is required to evaluate if a modification of the ROV unlock of WH Connector is required

HEME: 16.1.2023:
The proposed solution is not uncommon and widely used in the industry. The main reason for having such arrangement is due to the fact that pressure from the pods are not sufficient to release the connector. It is true that higher pressure on one chamber may not be enough but at least there will be a possibility to continue trying to release by one chamber through the ROV port if one chamber should fail during the process. In the end the wellhead needs to be cut if all possibilities have failed. Need to conclude if this is a concern and should be covered under continuous improvements

8.10 ROV isolating valve for Accumulator dump.

There is no means to isolate the subsea mounted accumulator dump valve in case this valve starts leaking during operations. The consequence of NOT having this shut of valve will be major downtime and risk to equipment, well and personnel because the well needs to be secured, BOP pulled and repaired before re-running the BOP. A leaking dump valve is not unlikely; hence this safety precaution has been installed on most rigs operating on the NCS, including all other Odfjell rigs. Lack of possibilities to isolate a major leak through this valve may also compromise safety because the well needs to be secured prior to pulling the BOP for repair. Any major leak on the HP/Acoustic dump valves may have considerable effect on being able to use the Acoustic or HP shear bottles during the time from spotting the leak until the well is secured.

Odfjell to install a manual ROV isolation valve after the accumulator dump valves.

SS – 31.03.23 Closed – This would have been a nice feature to have, and It Is possible to do this upgrade. However, due to timing and the implications of doing the upgrade and that it has not been a problem in the past, a decision was made by OMV, Wellesley and DNO to not go ahead with the upgrade.

SS – 20.02.23 Closed in the OD system – Cost estimate for extra isolation valves (Need 2) provided. DNO/Wellesley to approve if continue with this solution.

STIM 04.01.23 This is not safety issue, its a commercial issue.

NORSOK Z-013 not relevant.
This is not specified in contract, but can be implemented at client cost. Owner has declined cost for this modification.

RBV 30.1.2023: Considered closed for OMV since unable to install prior to OMV Eirik well. However, OD to provide Wellesley / DNO with a quote for implementing ROV valves prior to the Wellesley / DNO wells.

Do not fully agree with OD conclusion but it is operator that need to conclude. Most other rigs have installed such valve due to a reason. PSA require continuous improvements for operating on NCS and this is one such improvement because it will (by a leak on the dump valve) prevent pulling the sack that involves danger for personnel and equipment.
A leaking valve will also result in reducing the HP shear bottles to operate as intended during the period the BOP is installed prior to being able to pull to surface. Using the phrase that owner is not willing to take cost may not be a good excuse for documenting that continuous improvement is not taken into account.

CSV-17-01.2023 (Comments in Meeting): OD will provide a quote for the valves and forward the the confirmation to OMV Criticality was reduced from A–>B during the meeting.

8.11 Operational procedures.

Ref. Neptune report related to L-4 procedures item 4, 5, 6, 8 under chapter 7.3. Several were reported updated/corrected and closed in Synergi, however the verification team found that several of these procedures were either not updated, or were updated incorrectly i.e. with wrong content despite recorded as done in Synergi. Using or leaving wrong (non revised) procedures or procedures which have not been quality checked before being made available in the CMS/Rig CMS can lead to impaired Operational Barriers

Odfjell did correct several of these procedures during the verification, but the verification team was not able (time constraints) to verify the updated procedures. Odfjell to doublecheck critical procedures for correct content and details. This is because several faults were detected in the well control related procedures.

SS – 20.02.23 Closed in the OD system

21.01.23 Bjbe Acustic test on stump procedure is updated with correct CMS no and removed text about small capacity in acoustic retur line. BOP close in procedure updated. Removal of accumulated gas in BOP i updated.

RBV-23.01.2023 we agree to change status of Findings # 8.11 (Synergi case # 229337) from Cat. A to Cat. C expecting that OD will present a plan for review and update of other critical (to be defined by OD) L4 procedures with an expected due date. Also OD must update current L4 procedure BOP INNSTENGNINGSINSTRUKS “L4-MODU-DSY-B-WI-607N” to include handling of Nonshearable tubulars e.g BHA/DCs, Corebarrels etc. To be followed up

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation.

8.18 Temperature rating for line between Manifold and Poorboy.

Odfjell could not verify the temperature requirement of -40C on the line between choke manifold and poorboy degasser. Poorboy has a rating of -46C

Odfjell to reply on design temperature of this line. If not according to requirement a risk assessment to be performed. Alternatively other means to prevent low temperature in the line or make a deviation to the requirement.

SS – 20.02.23 Closed in the OD system. Line is according to DNV-OS-E101 which is the standard OD follows.

STIM 02.01.2023 Request for assistance forward to engineering, awaiting feedback. STIM 03.1.2023 Spec sheet attached, temp rating is -29 to 121C. STIM 10.01.2023. VTC/OMV to inform Odfjell if this is not sufficient.

RBV: 27.1.2023: Can be derated from Cat B to Cat C based on the provided documentation however, the suggested MOC should in fact have been a NC (Non conformance/Deviation) with compensating measures. OD to evaluate and also check if suggested corrective/mitigating measures are correct e.g. using steam hose to increase temperature in line between KC manifold and MGS.

If the -29 C is sufficient for the upcoming operations this should be OK. Operator need to accept and close this item. Consider a deviation against requirement of -40C.

CSV-17-01.2023 (Comments in Meeting): OD to provide a risk assessment and compensating measures. To be forwarded to OMV.

8.19 Use of Synergy

During the verification several previous findings were checked. Many items were closed out in the Synergi system, but during the verification revealed that they had not been closed or closed based on unacceptable reasons/explanations.

Odfjell to consider the way Synergi is used to ensure issues/nonconformities are properly closed out when the action(s) has been verified closed, and NOT when the action is entered in the system. OD to review/revise how Synergi is used by the various Authors to ensure there is a common way of reporting and documenting close out of records/entries.

SS – 17.07.23 Spot checks performed as part of the Vår Energi rig intake and found OK. Considered closed.
SS – 20.02.23 Approved in the OD system

RBV-27.1.2023: Thank you John Anders we confirm that we will derate the Finding 8.03 and 8.19 from Cat A to Cat C based on provided documentation and action plan described in Synergi Cases 229328 and 229311. Follow up and evaluation of effectiveness of implemented actions should be done on a frequent basis during operations commencing with the Eirik operations i.e. this should be a topic for the regular joint HSE status meetings.

RBV -24.01.2023: Finding 8.19 together with Findings 8.03 and 8.04 will be declassified from Cat A to a Cat C findings upon recieving an action plan addressing what OD will do to improve the process of identifying, recording and handling and Non-conformities, and also to ensure proper identification, reporting and reinstating impaired Technical, Operational & Organizational barriers.

8.08 ROV training using hot stab system

No requirements in OD CMS procedures for training of ROV operators to operate Hot Stab system on BOP.

Odfjell presented a new procedure during the verification (ROV training using Hot stab system has been implemented to L4-MODU-DSY-B-PR-312N). Odfjell to ensure that the ROV training is performed even if the procedure has not been implemented in CMS for the upcoming wells. Implementing the training into the ROV company procedure is outstanding and needs to be implemented when the ROV crew is back on the rig.

Henry Meling commented
Closed based on OD confirming that procedures are created

STIM 03.01.23 point 4.19 made in prosedure L4-MODU-DSY-B-PR-312N for ROV training.

ROV personel not on bord at present time, will be informed when they return to rig. Have also made a procedure for how to use flying lead, L4-MODU-DSY-B-WI-610.

Status Completed

8.12 Critical check valves in the BOP control system

There are several critical check valves in the system and if failure in holding pressure the system may not work as intended. No specific PM routine for verifying sealing capability of these valves. At present the test/PM procedures are not according to requirements.

During the verification Odfjell identified critical valves and made procedures for verifying capability. The procedure is a new one that has not been implemented yet but will be tested prior to commencement and when found to be sufficient it will be a part of the Stump test for the Yantai. Odfjell to ensure testing of the valves regularly even if the procedure has not been implemented in the PM system during the upcoming wells.

Henry Meling commented
Closed based on OD reply that IBWM routine is updated and by that the subject valves will be verified prior to first well

​Comments/status STIM 03.01. All valves has been critical evaluated, this has been shown to VTC/ Meling.

Check of critical valves has been implemented in IBWM prosedure.

Status Completed

8.14 Spare parts for WCS

DSY may not have the expected number of spares and Odfjell could not present a critical spare inventory list. Odfjell could not demonstrate that they meet the requirement described in PSA requirements for having performed the classification work as described in Z-008 that also shall lead to spare part selection. According to Odfjell the Yantai have spares based on the OEM proposed spare part items.This finding was also identified during the OMV verification (February 2022):Spare part evaluation.

PSA Activity §46 Classification «The classification shall be used as a basis in choosing maintenance activities and maintenance frequencies, in prioritizing between different maintenance activities and in evaluating the need for spare parts.
Norsok Z-008. Risk based maintenance and consequence classification: chapter 11, Spare Part evaluation

RBV 26.1.2023:  Closed based on provided information​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.15 Verifying acoustic accumulator volume

The method to ensure that the subsea accumulator bottles capacity for the acoustic system is not sufficient to document capacity prior to installing the BOP on a new well as expected in the regulations. The subsea accumulators are more important than the surface accumulators and an alternative mean to check changes in pressure/capacity is to note pressures before and after operation. The subsea mounted HP Shear bottles are tested this way, but the acoustic bottles do not have this check at present and need to be implemented.

Odfjell to implement procedure for checking the capacity of the acoustic accumulators. The remaining pressure shall be above MOP (minimum operating pressure) as defined in API16D/API S53. Odfjell to modify the existing stump test procedure to include note of pressure in the bottles prior to and after having function tested the acoustic functions.

​Comments/status STIM 03.01.2023:Check of pre-charge on IBWM according to NORSOK D-010. No bottles has been removed or added since commencement or other modifications.

Testing regime for DSY is NORSOK D-010. The capacity of acoustic acc. is verified by OEM calculations.

Status Completed
​

Henry Meling commented 16.01.2023:
I would like to go a little further here and ask for the original documentation and calculation results for the acoustic system just to ensure that they are within the requirements in API 16D for such system.

​​CSV-17-01.2023 (Comments in Meeting): OD will update procedure and forward the close-out data/documentation

8.16 Auto-Shear Trigger Valve

Malfunctions have been reported on other rigs related to this actual valve. The Verification Team does not have specific details on the exact reason for failure. Failures mentioned are unintentional activation, and not activating on demand when lifting off the LMRP. Other contractors have replaced this valve design (mechanically operated) with another improved and more reliable design (pilot pressure operated). The trigger is installed and serve as a safety critical purpose, mainly to trigger the casing shear and blind shear when the LMRP is disconnected. It is a backup for the deadman system and by that it is a safety critical valve installed on the BOP. A failure on demand may have big consequences. A critical valve that has proven to fail in the past needs to be improved or exchanged with a new item that has been proven to work according to requirements.

A valve, meeting the requirements for critical equipment, needs to be installed, or a proper risk assessment documenting that the installed valve is according to requirements related to safety, SIL2 and continuous improvement.

​​STIM 04.01.23 PM for inspection and overhaul to be implemented. STIM 11.01.23 IFS CASE made for new 12 mnd PM, CASE nr 130112.

RBV:  30.1.2023:  Closed based on provided documentation​RBV: 27.1.2023: Based on “”last minute”” input/documentation this finding is reclassified as a Cat B finding.  ​OMV will, as a final assurance of the status of the Autoshear trigger valve, require that the trigger valve is dismantled, inspected, witnessed, greased and reinstalled and tested, in addition to the updated PM routines , prior to RTO or subject to running the BOP (ref definition of Cat B findings).  This is required since the valve will not be replaced/upgraded for the OMV operations

RBV-26.1.2023:  Finding declassified from Cat A to Cat C based on provided documentation from OD, however OMV requested to perform an evaluation of the current auto shear trigger valve design to conclude whether the current design is reliable enough​

​OD to forward the new procedure and present the risk assessment performed that describe the concerns with the valve and how the new procedure handle the failure mode experienced on other rigs and how the new procedures prevents such malfunctions to happen on Yantai.

​​CSV-17-01.2023 (Comments in Meeting): OD has made a new PM and possibly risk assessment and forward the close-out data/documentation

8.17 HPHT Seals on Well Control Equipment

Odfjell plan, according to contract, to exchange all seals to the highest possible temperature rating available as required in standards. Odfjell could not verify if they have the correct seals in the K/C stabs between the BOP and the LMRP related to HT.

Odfjell to install seals on the stabs that correspond with the other K/C line system specification related to HT operation. K/C seals for riser on order with +176 Centigrade rating

​RBV: 27.1.2023:  Closed based on provided information.  OMV DSV to verify / confirm update of L4 procedure

8.20 Early Kick detection system

Especially related to HPHT operations a system for early detection of kicks shall be installed. The verification team was unable, based on provided documentation, to confirm that the secondary flow meter system was fulfilling the requirements.

Odfjell to present documentation that proves that the installed system is acceptable as an early kick detection system according to Norsok D-001 section 6.43.3.

​STIM 15.01.2023:  Se vedlagt dokumentasjon for vår Vegapuls sensor, på side 81 ser du angående responstiden (450 ms).
 
Sjekket på flow-teknikk sine sider og der står det at deres corialis har kjapp responstid (til mindre en 0.5sek/ responstid<500ms).
 
​RBV:  27.1.2023:  ​Based on information provided by OD, OMV find that the 2 independent “flow meters” installed on DSY are acceptable for operations on the Eirik wells

8.21 Bypass Loop MGS

A bypass loop on the MGS was not installed at the time of verification, however the verification team was informed that Odfjell was working on a project for installing a new line that will meet the requirements.

Odfjell to present documentation that proves that the installed system is acceptable as an early kick detection system according to Norsok D-001 section 6.43.3.

​Regarding the bypass loop MSG (229346) its 65% finished.
No reported show stopers her.
 
​​RBV:  30.01.2023:  Awaiting confirmation from rig that lines have been physically tested.

​​​CSV-24-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, Estimated to be finished the 25th of January

8.22 Internal Audits of Electrical Installations

Odfjell could not document having performed internal audits regarding electrical installations and systems since DSY started operations in 2019.

Odfjell has a dedicated responsible for electrical system which has the overall responsibility for work practices, safety and integrity of electrical systems.

The responsible person for electrical systems has a scheduled internal audit every 2 years. The rig crew explained that an internal audit was planned early in January 2023. The results from this audit should be forwarded to the rig intake team.

Odfjell should ensure compliance to regulations and perform the bespoken audit in due time before operation starts for OMV.

​Comments/status 06.01.2023 BJES:
Notification for E&I audit sent rig 16.12.2022. Verification will be performed 10-12.01.2023. Based on this action is closed.

Status Completed

​​CSV-27.01.2023: Downgraded to C based on that the audit is performed.

​​CSV-16.01.2023: Finding will be closed when Odfjell submits documentation for completed internal audit.

8.23 Smoke detection-in Accommodation Air Intake

Smoke detectors are not installed in the air intakes for the Accommodation. Ventilation systems for accommodation spaces and control stations shall be arranged in such a way that the penetration into these areas of any flammable, toxic and noxious gases and smoke is prevented.

Smoke detectors shall be installed on all intakes for ventilation air to accommodation spaces.

Odfjell must implement measures to comply with the applicable regulations.

Comments/status 29.12.22 JORG: Smoke detectors are installed inside Air Handling Units for accommodation.

Pictures attached.

811BSFS203-338, 811BSFS203-433, 811BSFS205-334 & 811BSFS205-440

Status Completed

User responsible for action DSY E&I Supervisor” CSV-16.01.2023: Based on the submitted documentation this finding can be closed

8.24 Floodlights towards sea-Lifeboat stations

It was not installed dedicated light sources for illumination of the sea where lifeboats shall be launched.

At the FWD Lifeboat station it was installed 4 floodlights, however these were not directed towards the sea.

AFT Lifeboat station did not have any floodlights towards sea.”

Odfjell must implement measures to comply with the applicable regulations and AoC.

29.12.22 JORG: Both FWD and AFT lifeboat drop zone has four designated floodlight 400W supplied form UPS power. All in good working condition. Drop Zone Floodlight FWD: 866EL006.22-E01 – 866EL006.22-E02 – 866EL006.22-E03 – 866EL006.22-E04 Drop Zone Floodlight AFT: 866EL006.09-E02 – 866EL006.09-E03 – 866EL006.10-E01 – 866EL006.10-E03 Located on railing mezz deck level. (Lower level compared to fwd.) Pictures attached to synergi.
​
CSV-17.01.2023: This finding can be closed based on the submitted documentation.

8.25 System for recording helideck movement

The system for recording movements on the helicopter deck was not connected to a repeater light (light system), which shall be activated when the movements exceed the limitations.
Red flashing lights (repeater lights) around the helicopter deck must be activated automatically when the set limit values for movement are exceeded, identical to the red traffic lights presented on the HMS screen. The repeater light must be visible to the helicopter crew from all directions of approach and when the helicopter is on the helideck and must be dimmable so that it does not dazzle the helicopter crew.

The revised regulation take effect from 01.01.2023. Odfjell must implement the system before operation.

​CSV-17.01.2023: Closed based on KM-Service report-see attachment

8.26 Electrical Safety

Necessary measures had not been taken to avoid dangerous and accident situations related to work in and operation of electrical installations. Several weaknesses related to electrical safety was identified during the offshore survey. Arc-flash energy levels were not available onboard the rig or known by the crew Marking of arc-flash energy levels in the switchboard rooms and electrical distribution boards was not performed. Personnel on board had not completed relevant courses/training related to work in/nearby facilities with high arc flash energy levels. Protection suite for the highest energy levels (PPE 4 Suite) was not available onboard the rig. High Voltage switchboard rooms were not physically locked to avoid unauthorized personnel entering. Safety card for the EIT lead onboard was not updated with the correct permissions. The company responsible person shall issue and control the permissions for all crew members. It could not be documented that safety equipment was part of the maintenance system, and it was not tagged.

Odfjell must ensure that required precautions related to safety when working on electrical systems are met

SS – 20.02.23 Closed in the OD system

​16.01.23 Bsku: Marking labelling of arc-flash energy levels for each of the rigs switchboard are produced and completed

16.01.23 Bsku: Marking labelling of arc-flash energy warning sign description installed in all Switchboard room’s

16.01.23 Bsku: Protection suite for the highest energy levels (PPE 4 Suite) ARC CLOTHING: GORE-TEX PANTS ELECTRIC ARC in order on Rekv. 5007405. Leveringstid ca noen uker, innkjøp arbeider med eksakt dato

16.01.23 Bsku: Odfjell standard, HV  rooms kept open, HV equipment is fully protected against live parts as all HV parts are insulated inside an DNV Approved switchboards quite common solution and used throughout the industry.

16.01.23 Bsku: Access card and registration is controlled by Odfjell Procedure L3-MODU-ALL-TO-PR-018 key factor HV certificate, FSE Nominated person  access control Layout of the rig ( no other equipment in rooms, Switchgear construction completely isolates HV parts, Interlocks. As DSY are in a situation where some crew members will be new, access cards and access register  need to be updated when names in position is defined, however access control and safety for HV system is exactly the same and of high level. New access cards are produced by MODU-TS Senior Engineer Electrical Systems “”Vedlagt finn De oppdaterte adgangskort til HV-romma på Deepsea Yantai.Vennligst sjekk at det stemmer før det utsteder og henger opp listene ved inngongen til HV-romma.
Det blir sjølvsagt ein del endringer på listene framover, men dette skal reflektere dagens status.

22.01.23 Bsku: El. PPE ( Electricians safety equipment ) is part of the maintenance system, inspected on annual basis and performed 3 times, section 442.100.600 in IFS

EL. PPE shall not be tagges as can degrade isolation protection capability, however a register have been  worked out and contain unique location, serial number and all part been inspected ( even IFS job will be generated as normal)

​CSV-26.01.2023: OD will provide a list of and status for personnel that have completed the Unitech-course. It will be emphasized that personnel on board have completed the course. The competence matrix must be updated to reflect this course.

​CSV: 24.01,2023:Arc-flash energy levels were not available onboard the rig or known by the crew Can be closed when OD confirms that all relevant crew members has performed the applicable training. Marking of arc-flash energy levels in the switchboard rooms and electrical distribution boards was not performed. Can be closed based on the submitted documentation Personnel on board had not completed relevant courses/training related to work in/nearby facilities with high arc flash energy levels. Can be closed when OD confirms that all relevant crew members has performed the applicable training. Protection suite for the highest energy levels (PPE 4 Suite) was not available onboard the rig. Can be closed based on the submitted documentation

High Voltage switchboard rooms were not physically locked to avoid unauthorized personnel entering. Can be closed based on the submitted documentation Safety card for the EIT lead onboard was not updated with the correct permissions. The company responsible person shall issue and control the permissions for all crew members. Can be closed based on the submitted documentation It could not be documented that safety equipment was part of the maintenance system, and it was not tagged. Can be closed based on the submitted documentation
​
​CSV-17-01.2023 (Comments in Meeting):Ongoing from OD side

RBV-23.01.2023 OMV agree to derate Finding from Cat A to Cat C based on provided documentation.  A new due date for closure has been set to 28th of February.  OD to provide documentation/confirmation when all issues have been closed. 

8.27 Ventilation Systems

Measures to ensure that there is sufficient overpressure in “safe areas” at all times were insufficiently tested and adhered to. Examples: Fire dampers for air intake to living quarters does not close automatically when registering low-level gas detection. During review of online C&E it was identified that HVAC inlets to accommodation did not shut automatically until “confirmed-gas” (High-level, 30% LEL) was activated. Alarm limits for HVAC were not set in accordance with regulatory requirements. The alarm delay-time (max, 30s) were adjusted above requirement for several differential pressure transmitters. Some transmitters had alarm delay for 120s.Odfjell could not present a TBAMI job for calibration and testing of the integrity for rooms classified as “safe by ventilation”. There were no differential pressure transmitters installed that made it possible to read actual over/under pressure in, for example, living quarters.

The living quarter was equipped with pressure switches, giving a digital signal to K-Safe, OD could not present a calibration job for these switches.”

Odfjell must ensure that areas that are categorised as “safe by ventilation” maintain the integrity at all times and that potential ignition sources are de energized if the integrity is weakened/lost

​Comments/status- A – Fire dampers for living quarters close Automatic according to C&E at confirmed gas Low Level 10%LEL. (Confirmed Gas: Two detectors in Low level or One detector in High level) Print of C&E and F&G performance standard Attached print out of C&E.
– B – KM onboard to update time delay according to regulations. 30 sek.

Update will include all diff press sensors displayed on KM HMI. Attached tag item list.

08.01.23 JORG: WO 26006185 raised to secure history.

KM by Andy Trinh has updated all diff press sensors according to regulations.

All set to 30 sek delay.

Attached KM service report as documentation.

– C – Record of TBAMI jobs and TBAMI performance standard for Diff Pressure Switches attached.
– D – We do not have any pressure transmitters for remote reading of overpressure in living quarter installed on DSY.

Differential pressure switches are installed to monitor overpressure level at 50 pascal. KM

Safety monitor and display these readings.

Located close to Diff Press Switches there is an analogue gauge installed to read actual overpressure.
Attached picture.

​RBV: 28.01.2023 Finding to be closed based on final received documentation
CSV-16.01.2023:

a)Considered to be closed based on the submitted C&E and FDS, and OD’s definition of LOW-level gas and the defined voting principal.
b) Considered to be closed based on the submitted KM service report-See attachment.
c) Needs Clarification-Please forward the TBAMI job – ​CSV-17-01.2023 (Comments in Meeting): Bjarte Fadnes will forward the information.
d) Considered closed based on submitted documentation”

8.29 Systematic Mapping of Ignition sources

Nonconformity from OMV Audit (Feb.2022) – Not Closed

Odfjell could not document to have performed a systematic mapping of non-electric ignition sources (mechanical). In order to fulfil PSA, Facilities regulation section 10a: «In order to prevent and protect against ignition of combustible liquids and explosive gases, a systematic mapping of potential electric and non-electric ignition sources shall be performed. In addition, the necessary technical, operational and organisational measures shall be implemented so as to reduce the risk of ignition as far as possible».

Odfjell explained that the analysis was partly performed, but the offshore part was not done for Deepsea Yantai.”

Odfjell must document that the mapping is performed and that measures are implemented.

​Comments/status “”29.12.22 JORG: Mapping of Non electrical potential ignition sources was performed during yard stay in Okt.22. Inspection used as platform and identification of equipment ID.

KNB 05.01.23: EIT Jørgen holder på å lukke saken i Synergi

08.01.23 JORG:

Attached print of Inspection dashboard for Mapping Of Non Electrical Ignition Sources. 99% finish.
Status Completed

RBV: 30.1.2023:  Still awaiting for some final documentation​

CSV-26.01.2023: There are currently 37 items that have been recorded as “”failed”” in the inspection database. If OD can extract a list of these items and evaluate the criticality for the failed items we will be able to determine the ​extent of required repairs. The jobs must be recorded and documented in IFS.
​​
CSV-24-01.2023 (Comments in Meeting): OD will arrange a teams-session to review the Inspection

​CSV-16.01.2023: Needs clarification – Have all recommendations from the mapping been implemented? What are the remaining issues in Synergi? 

​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.30 Emergency Ex-flashlights

Portable emergency flashlight was not installed in Drilling Control Room, Marine Control room, OIM Office, TSL Office and Engine control room.

These flashlights are to be located in readily accessible places in the control rooms and shall be of a type that is constantly charged and be certified for use in a hazardous area, zone 1.

Install portable flashlight and include in ex register and maintenance system.

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation/pictures
Flashlights have been received onboard, -but not installed?

RBV-20.01.2023:  Finding closed based on received information

8.31 Emergency Stop for Thruster motors

Emergency stop buttons for thrusters are not located in the vicinity of rotating machinery.

Thruster rooms 1–> 6 are equipped with emergency stop buttons, which are located on the VFD Switchboards on Mezz-deck.

Odfjell must ensure that people are not harmed by rotating machinery.

21.02.23 JKAA: Risk assessment updated in Synergi and document is sendt to VTC for review.​ Comments/status

29.12.22 TFYL: Sperringene rundt thruserakslingene er gode nok slik de er. Foreslår å lage et skilt som varsler om roterende utstyr på rekkverket som et tiltak.

KNB 06.01.2023: We have now made large, red warning signs and put them up on the handrails in all Thruster rooms.
Text on sign: “” WARNING – ROTATING MACHINERY – PTW REQUIRED TO ENTER “”. See attachment

Status Completed

CSV-24.01.2023: Findings is considered closed by OMV, based on the submitted risk assessment (see attachment)​CSV-16.01.2023:

Not considered to be closed. The thrusters are already equipped with an emergency stop button which is placed on the VFD switchboard, on mezzanine. However, if the intention with the function is to rapidly to avert threatening situations or limit the impact of dangerous situations that have already occurred, the button on the VFD will not fulfil the function.

The emergency stop device must:

– be easily recognizable, have clearly visible and easily accessible operating devices,

– stop the dangerous process as quickly as possible without resulting in additional risk, The emergency stop function must be available and work at all times regardless of the mode of operation.

The emergency stop devices must supplement other safety measures and not replace them.
https://lovdata.no/dokument/SF/forskrift/2009-05-20-544

​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation/risk assessment/procedure

8.32 Ignition source control

​In addition to findings 8.33 and 8.31 the following items should be followed up:

Outstanding corrective work orders for Ex-equipment should be followed up to ensure that all Ex-equipment have the integrity as per design, -before commencement. The total amount of outstanding corrective jobs were 90, at the time of the audit. Odfjell had engaged personnel from Westcon to finalize these jobs, the goal was that all 90 jobs should be corrected prior to commencement. OMV will follow-up the progress and status. Battery powered hand tools are not recorded and maintained. Tools should be tagged and appropriate maintenance program should be implemented.

Battery-powered equipment that was not of Ex design was deployed in an area where potential sources of ignition were to be removed by gas detection. (Battery powered vacuum cleaner DCR, battery tools in workshop on drill floor. Also applicable for the deck cranes.”

Odfjell must ensure that all corrective work orders for Ex-equipment are finalized and evaluate system for battery powered appliances and tools.

​Some specific facts on  Rig Intake DSY  Finding 8.32/ Synergi Case229331 Ignition source control:
In general we have done annual checks of all portable tools etc as described in Odfjell procedure, register as reflect rig per today, maintained and repaired electrical tools found to need so, labels up all tools after approval from inspection we did, attached a informative performed job, below cut our from IFS system showing annual jobs ( performed as in Historical WO)
EX repair, status as below, some materials expected on 27/1 we will continue with Westcon when we have materials in place.
Awareness use of portable electrical tools ( and under work permit have been noted shall be part of safety meetings)
a)Outstanding Corrective work orders for EX Equipment should be followed up ( Criticality B)…, Odfjell are working with Westcon as we speak to rectify findings from EX inspection, status per today is 21 open low critical Ex repair job reaming, some we are waiting part for from Westcon, informed delivery date 27/01, typically Tag Numbers, EX labels IP washers, so low critical items, Based on this Odfjell believe this comment can be changed criticality on frm B- to C or closed as minor issues

b) Battery Powered hand tool are not recorded and maintained , Not correct as IFS have historical work orders reflecting Odfjell Procedure for annual inspection and re- labelling, example of register Maintenance portable elec. Equipment, this register and equipment I field have been checked out, arranged labelled after inspection and cut out from IFS, Based on this Odfjell believe this comment can be closed

c) Battery Powered equipment found in DCR,   Vacuum Cleaner removed, Based on this Odfjell believe this comment can be closed

Battery Powered tools in workshop on drill floor, workshop not part on EX zone, however use of battery power tool require work permit, Based on this Odfjell believe this comment can be closed

Battery Powered tools in deck cranes are removed, and usage of such only under a valid permit to work ( same as rest of the rig),Based on this Odfjell believe this comment can be closed

​​CSV-25-01.2023: Based on OD’s comments and documentation this finding criticality has been​ reduced from Cat.B–> C. The finding can be closed out when remaining Ex equipment are repaired and signed-out in the maintenance system IFS. 

​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.33 Chiksan on Drill floor

Several Chiksan items were missing ID-number, spot checks were made on drill floor equipment.

OD must ensure that flexible threaded piping systems (Chiksan), are marked maintained and have the correct documentation.

​DSY DSL 22.01.2023 Refreshed color coding on all BX inserts

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

RBV-22.01.2023:  Finding to be closed based on received information

8.34 Calibration of instruments on Cement unit

Pressure gauges on cement unit, was due for calibration April 2021.

OD must ensure that critical drilling instrumentation are maintained and calibrated.

​Martin Decker gauges for pressure are now marked with “”Reference Only”” (See image in attachment)
These gauges are not used for logging and staying on a pressurized unit is not something we practice in Norway.
 
It is standard that the unit is delivered with an MD gauge and map reader in addition to the remote system. Pressure sensors for the remote system are calibrated annually.

​​​RBV-22.01.2023:  Can be closed based on received documentation

CSV-17-01.2023 (Comments in Meeting):OD will forward close-out documentation

8.35 HAZID for manual pipe handling

The Hazid related to manual pipe handling had expired due date for renewal.

HAZID shall be repeated at least every 3 years and in relation to changes that will affect the pipe handling. Document received for Last HAZID related to manual pipe handling was done 05.2019.”

OD must perform new HAZID and update deviation matrix if required. Also ensure that all relevant material handling equipment are covered in the HAZID e.g. drillfloor manipulator arm.

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.36 Maintenance related to Barrier Elements, Firewater Pumps

Acceptance criteria for flow measurements, in the performance standard for main fire pumps, was not recorded during performance testing.

OD must ensure that accept criteria in performance standards for barrier elements, are tested and maintained if required.

SS – 20.02.23 Closed in the OD system
​
Comments/status KNB 03.01.2023:

Regarding Accept criteria and doing the TBAMI jobs strictly according to the Performance

Standard the following can be said:

We have lately had special focus on this and informed crew about the importance of this matter.

As a “positive” result of the above, i.e., the testing of Rig savers (mentioned in VTC report 8.4) was reported as failed because the test procedure could not be followed to the letter with the expected result (even if we suspected errors in the procedure that later proved to be the case).

For the annual TBAMI capacity test jobs for Fire pumps, the test procedure is stated in the Performance Standard document attached to the job.

The performance standard PS-SCE-FG2-03-T for capacity test of fire pumps states the following procedure to verify the capacity: TBAMI test PS-SCE-FG2-03-T:

———————————————————–

“” During this test 2 pumps needs to be running simultaneously.

Open two fire monitors in moon pool, release deluge on drill floor and open adjacent two fire hydrants at the same time.

Check system pressure (min.7 Bar) in one of the hydrants at Heli-deck. “”

———————————————————–

The test is considered “passed” if the measured pressure is minimum 7 Bar, and the corresponding “Route Actions” in the job are then set to “passed” or “failed” depending of result.

I hope this will clarify how the test actually is done and documented. The tests were all set in “passed” during last test (and previous as well.

Upon studying this specific performance standard (and test procedure) we have made a MMS CASE 5003680 to remove the passage “”..then verify/record the capacity on drill floor”” because that belongs a different performance standard (PS-SCE-FG2-05-T TBAMI Function test of deluge nozzles) and may lead to misunderstandings.

Status Completed

CSV-30.01.2022: We need the job-description (TBAMI-Job) to verify that wording complies with the performance standard.​​CSV-17.01.2023: Needs clarification,- Do the descriptions and acceptance criteria in the performance standard match the TBAMI job?

RBV-17.01.2023:  Not possible, based on feedback from Odfjell, to conclude whether the Performance standards are met wrt to Fire Pump capacity, ref. NMA 227, Chapter II Section 6 point 3.   It is also unclear whether the Rig Savers shall close upon activation of the Emergency Stop function or not, or if it is the Test procedure that is wrong.  Especially the latter has not been registered in Synergi and properly case processed , also ref. Management Regulations § 22.​​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, (TBAMI job and Performance Standard)
“

8.37 Follow up on last RBI report findings

Findings from last RBI report October 22, was not treated according to recommendations and no corrective work order had been generated in the maintenance system IFS.

OD must follow up reported findings from the last RBI report

​Comments/status Made jobs in IFS to follow up all findings from RBI 2022. Example: WO26006132 Status Completed

19.01.23 Janm

Two jobs was made to cover the finding on the jockey fire pump’s piping this is WO 26006133 & WO 26006134 these two jobs have been done.Status completed

​CSV-16.01.2023: Normally a finding is not closed out before documentation is provided. Example: Records of completed WO’s

8.38 Maintenance and follow up of loose lifting equipment

Follow up of findings in report after periodic control of loose lifting appliances done by competence of enterprise (CoE) was not properly done. When reviewing the last report after periodic control, done by excess in July 2022, it was revealed that 1 NC (fall arrest block) had not been taken out of service, and 7 RCs regarding Riser Lifting Lugs were missing approved certificates.
Furthermore, 1 RC on pipe handling machine. (Possibility for collision with other equipment) and 1 RC regarding missing certificate for weak link on pipe handling machine were not rectified within 3 months which is the deadline

OD to ensure that findings after periodic control done by CoE are followed up.

SS – Closed according to Synergi 229332
​
04.01.23 YNUL: New fall arrest blocks have been ordered on WO 26006066. Fall arrest block has been recertified and put back in use. RC in Axess/Equip is closed.

Weak link certificate received from Certex. RC in Axess/Equip is closed.

RC on ACS. The Dope application machine has been moved to forward side of HT and the collision danger have been reduced, NOV to be onboard in Feb./March to preprogramme the ACS function. RC in Axess/Equip is closed

21.01.23 JKAA: Certificates for lifting lugs received from vendor, however the certificates refer to API 8C and not NORSOK R-002.

OD has engaged Axess to preform control of documentation from vendor including inspection of these lifting lugs for recertification of the lugs. Due to ongoing rectification of the finding Acess has postponed the date for overdue to

28.02.23: Case to be kept open until we receive certificates of lifting lugs. Axess has this scope. To be follow up by SSL

​​CSV-16.01.2023: All actions are expected to be closed out in Synergi by the 28th Feb.

​RBV:  27.1.2023:  Closed on provided information

​​CSV-17-01.2023 (Comments in Meeting): Ongoing- OD will forward the close-out data/documentation

8.39 Loose lifting equipment – Field survey

Field survey looking at loose lifting equipment revealed several equipment not in accordance with requirements:
Fiber sling on drill floor, not allowed to use according to OD internal requirements Wire sling not marked with yearly color Lifting sling (chain) not marked with yearly color Lifting gear (forerunner for spider and gimble) was not marked with Axess “Tag” Lifting gear for inner bushing not marked with tag. (2-part chain)Lifting subs, ready for use, missing safety pin Storage racks in sack store missing SWL”

OD must make sure that all loose lifting equipment in use are marked and used.

​22.01.23 JKAA: The lifting equipment found on drill floor during inspection was immediately removed from DF.

Lifting gear for inner bushing were discarded and new equipment ordered (are now in place on drill floor, certificate uploaded in synergi certificate nr 579190)

Fiber sling as mentioned were discarded. 2 Wire sling were found without yearly colour and also missing tag, these were also  discarded and 2 new wire sling were ordered. 10m chain sling 15T missing tag was sendt to Certex for control/ recertification and new tag plate mounted by certex. picture of tag plate uploaded in synergi

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.40 Storage of loose lifting equipment

Locker room for new loose lifting equipment on mezzanine deck was not properly locked. During field survey it was revealed that an extra rigger loft above the main rigger loft was not locked. This can cause that lifting equipment can be used without required labelling and thus lose control of what is approved or not.

OD must make sure that the rigger loft is locked to ensure loose lifting equipment not in use.

​​CSV-17-01.2023 (Comments in Meeting): OD to provide close-out documentation.RBV-20.1.2023 .  Based on received documentation finding is closed

8.41 Mooring Lines CC 56 – wire damages on all mooring lines

Odfjell had not recorded the deviation/ dispensation in Synergi and could not present a risk assessment related to i.e., emergency release, move off from well center, use of mooring lines for emergency towing.
The damaged wires were “approved” for use in “normal operation”, for 2 wells: the previous “Calypso well”, and the upcoming “Eirik well”.
The weakened condition of the mooring lines was not treated as an impaired barrier with corresponding mitigating measures.
Has Odfjell carried out a risk evaluation where operations/circumstances beyond “”normal operation”” have been evaluated?
In July 2022 it was discovered wire brakes on mooring line #8. OD carried out a thorough survey of all 8 mooring lines by use of a 3rd party company Certex. ISO 4309:2017 for Cranes-Wire ropes- Care and maintenance, inspection, and discard, was used as conformity standard.
The report after the survey showed that none of the mooring lines passed the acceptance criteria set out in ISO-4309:2017.For more details regarding action limitation, see attached Narrative report from DNV.”

Odfjell must present/ document which risk evaluations has been performed related but not limited to:

1. Possible emergency release of the anchor cables to pull the unit away from the well center in the event of a blowout?

2. Anchor line 1 & 8 are dedicated for emergency towing, has this been accounted for?

3. Are well/field specific circumstances included in the evaluation?

4. Are weather conditions, winter weather, included in the evaluation?

ÅP: 17,08,2023 Surevy statement from DNV received and attached

SS-17.07.23. Closed. All damaged mooring wire lines were replaced. DNV to remove the condition of class (CC).
​Synergi 227190 was previously created to follow up this matter and will be open until the rig wires has been changed out. The Synergi created to follow up this finding from OMV (8.41) is proposed to be signed out when Rig Intake team finds the handling of this NC to be handled in accordance with proper handling of Non-Conformities

21.01.23 JKAA: Reply from DnV on CC-56 is attached in this Synergi. As stated in reply from DnV we will preform inspection when unmooring to verify if there is observed further development of thread break. Extended permission of use will be evaluated based on this verification (from DnV). The Mooring analyses for both Calypso and Eirik includes actions towards this CC with restrictions of a pay out owner well center to be maximum 180m, ensuring that all damaged areas is in the wire drum. The understanding of the statement “Normal-Operation” is that the rig is to be moored above one well center. PO286911 is created for 8 new rig wires including 2 spare wires. Change Out of wire is preliminary planned in February in due time before CC61 expires. (if extension permit not given). Synergi 227190 includes Wire damage risk evaluation. Wire damage reply from DV OD Wire Rope Evaluation

RBV ​26.1.2023:  Based on provided information the punch will be derated from Cat A to Cat C with a revised due date of end of Eirik well, where continued use of the damaged wires will be reevaluated.

Ref also the following comments from the VTC Surveyor:

Hei,
Jeg har gjennomgått dokumentasjonen og den ser ok ut. OD har gjort de risikoevalueringene som vi etterspurte, og de har en plan for å følge dette opp. I risikoevalueringen ser jeg at de har brukt kompetent personell som skjønner risikoen og forstår konsekvensene, så det ser bra ut. Det mest ideelle hadde vært å fått skiftet ut alle linene, men med de tiltakene/ forutsetningene som er implementert så tenker jeg vi må kunne si at det er ok for den kommende operasjon for OMV. Det må også legges til grunn at OD har en kontinuerlig fokus på dette gjennom hele kampanjen for OMV.OMV’s boreledere må være klar over situasjonen og kunne stille spørsmål underveis ang. status. (Påse plikten)

9.01 Change out of Rubber Compensators/flexibles

Rubber compensators/flexibles in pipelines are not Tagged or linked to equipment PM when to be replaced. Random change out can result in missing control of these items.

OD should consider change out of these rubber elements in the equipment PM based on criticality.

SS- Odfjell will consider change out of these rubber elements in the equipment PM based on criticality.

9.02 Color coding on BX elevator inserts

Poor/ missing color coding was observed on some of the BX elevator inserts. Odfjell explained that the color coding should be “refreshed” during the ongoing yard stay.

Color coding on BX elevator inserts to be refreshed.

​​DSY DSL 22.01.2023  Refreshed color coding on all BX inserts

9.03 Removal of the check valve on the WH Connector

Due to a requirement from OEM of the HDH4 connector Odfjell plan to remove this check valve. The OEM has a note in the manual saying that the HDH4 connector shall be locked by 3000 psi and then bleed down to 1500 psi. This action will not be possible with the pilot operated check valve installed because the initial 3000 psi has been locked in the system by the check valve. For most wells locking by 1500 psi is sufficient but OEM claim that 3000 psi may be needed for critical operations. The purpose of the installed check valve is to ensure that pressure on the lock side is maintained if the control system is disconnected e.g. by disconnecting the LMRP and the BOP is left on the wellhead. There is no specific requirement for this valve.

Odfjell to present a MOC for removing this valve. The operators need to consider together with Odfjell the need for using a locking pressure higher than 1500 psi and by that removing the check valve. Operator to evaluate expected load on the specific wellhead to be used.

SS- Considered closed by Wellesley and DNO, but needs to be considered on a well-by-well scenario if a higher pressure than 1500 psi is required.

8.28 Inhabitations of Safety Systems

Flame detectors in moonpool were inhibited without being recorded in the override/inhibit-logbook, located on the bridge.

Overrides in the fire and gas system are not automatically restored into normal surveillance after a predetermined time.

Overrides are controlled by the PTW (Permit To Work) system, however, the PTW did not describe that detectors needed to be disabled/inhibited.
Considered to be an impaired barrier.

Odfjell must ensure adherence to procedures /processes.

​17.01.23 NIIC: All crew have been told the importance in logging inhibit sensors on K-safe.
This findings have been filed in TM-Folder which the bridge crew are going through every week.

The CMS procedure are also updated. CMS 94256 and CMS 94257
The PTW system are also asking the CCR when activating the PTW, if there are any sensors which need to be inhibited doing this job.
And also if there are any sensors which need to be activated again after the job is finished and the PTW are getting closed

​RBV: 27.1.2023 Finding confirmed closed based on provided documentation

​​CSV-24-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, New L4 procedure is made and will be provided

​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.07 Preventing disconnect of wellhead connector.

The current system installed (Covers over functions) to prevent an unintentional disconnect of the WH connector during drilling by human or technical fault is not acceptable and not according to PSA,Norsok D-001 and Contract.

Odfjell to ensure that it is not possible to unlock the BOP due to a human error or system fault. A physical locking device on the HPU panel handles during drilling operation can be one solution to this issue.

From Synergi 229320:
For the annual TBAMI capacity test jobs for Fire pumps, the test procedure is stated in the
Performance Standard document attached to the job.
The performance standard PS-SCE-FG2-03-T for capacity test of fire pumps states the
following procedure to verify the capacity: TBAMI test PS-SCE-FG2-03-T:
———————————————————–
” During this test 2 pumps needs to be running simultaneously.
Open two fire monitors in moon pool, release deluge on drill floor and open adjacent two
fire hydrants at the same time.
Check system pressure (min.7 Bar) in one of the hydrants at Heli-deck. ”
———————————————————–
The test is considered “passed” if the measured pressure is minimum 7 Bar, and the
corresponding “Route Actions” in the job are then set to “passed” or “failed” depending of
result.
I hope this will clarify how the test actually is done and documented.
The tests were all set in “passed” during last test (and previous as well.

RBV: 31.1.2023:  Finding derated to Cat B.  Awaiting MOC and plan of action for WH Connector to be secured ​​​

RBV:  30.01.23: OD (Bjarte Fadnes) to require this Finding to be derated from Cat A to Cat B prior to  conducting an MOC to be able to  upgrade the system.  However,now (ref. mail from OMV DSV regarding this matter) it appears that the rig has solved the problem on their own and that they are in the process of installing an acceptable solution.  Has to be sorted out + documentation of selected solution and confirmation of installed system is outstanding
 
RBV: 27.01.2023:  A safety device to be installed to prevent unintended disconnect of WH connector during normal operations

RBV: 27.01.2023: Provided “evidence” explaining why a locking/safety device will NOT be installed on DSY (which can prevent the WH connector to accidentally disconnect (either by human or technical errors) is not found acceptable

RBV: 26.01.2023:  Awaiting:

1. MOC/risk assessment, addressing why a safety device, which will prevent the WH connector from being disconnected inadvertently, either by human errors or technical faults, will not be installed on DSY and that the current arrangement is considered to fulfill all functional requirements. 
 
2. Also we need a statement from both the OEM and DNV stating that a safety device, as described by OMV, is not deemed necessary, or that it is considered to increase the risk of malfunction of the actual functions

RBV:24.01.2023: OD to revert with a MOC/Risk Assessment justifying why a locking/securing device, which can prevent the WH Connector from being activated i.e. go to disconnect mode as a result of either human or technical/system error, will not be installed on DSY

​SV-24-01.2023 (Comments in Meeting): OD states that they will not modify a DNV approved design/system. OD has however not forwarded a risk assessment with relevant arguments for not performing the action. OD will Forward the argu​ments.

8.13 Pressure reading on manual choke valves.

The Pressure gauges installed on the Choke Manifold has a scale which makes them unsuitable in case of circulating out a kick in well control situation and by that not meeting requirements.These gauges will have to be used, if using the manual chokes during a well control situation, and with a scale spanning from 0-20000 psi they are considered more or less useless.These types of gauges are not sufficient to be able to identify low pressure that is the most common scenario when a kick is to be circulated out.

A system that can detect and show low pressures more accurately to be installed close to the manual chokes.

Synergi 229339
Approved and DNV certifies as is. Gauge measures steps of 25 psi (1,72 bar). It is meant as a backup system in the event power and HPU fails. Feedback from drilling personnel is that it works fine when handling kick using this gauge during choke drills. Also, no proper solution available.

RBV: 31.1.2023: Documentation still pending.

RBV:27.1.2023: OD to present action plan for upgrade of current gauges.

CSV-17-01.2023 (Comments in Meeting): OD are waiting for DNV approval -will not be in place before commencement. OD to forward the plan/ time estimate for how this will be solved

8.01 Recording and documentation of Emergency Training.

A spot-check of the Emergency Drill and Training Program for a specific week (46) revealed a deviation between scheduled/planned Drills and Exercises and actual performed Drills and Exercises.14 (1 Drill & 13 Exercises) vs. 8 (1 Drill & 8 Exercises). This non conformity was not flagged or recorded in Synergy.

DSY has established separate systems for planning / scheduling of Drills/Training (Drill Matrix) of Emergency Team and recording of actual executed Drills/Exercises (Rig Manager).There is no direct communication between these systems, hence there is no flags/alarms warning the responsible that Drills/Exercises are overdue or not executed or reported as done.

The nonconformity is not actively acted on since it requires an active investigation by the responsible user, hence it is not recorded as a nonconformity in Synergy where it can be acted on.

The identified discrepancy between planned Drills/Exercises and Performed (recorded) Drills/Exercises may indicate a weakened or impaired organizational barrier with regards to emergency preparedness.

OD must document that all emergency training is performed and recorded as planned / intended to ensure that barriers related to emergency preparedness are maintained. Any discrepancies between planned Drills/Training and Actual performed Drills/Training must be treated/recorded as a nonconformity in e.g. Synergy

Also, OD should evaluate and or improve current system for planning and recording of drills/exercises and routines for using these tools to prevent recurrence of these nonconformities.

SS- 17.07.23 Spot checks performed as part of the Vår Energi Rig Intake process and found OK.

SS – 20.02.23 Approved in the OD system

RBV-24.01.2023 Based on the provided information we will change the criticality from Cat A to Cat C with a new Due date for final closure of Finding 8.01 set to 31st of March.The OMV HSE Coach will follow up to confirm that the implemented measures works

19.01.2023 JKAA.As described, discrepancy between the drill matrix and the actual logged drills/training were observed. Routines for weekly follow up by SSL is established to ensure that all exercises/training tasks has been met and to ensure quality of logging including the evaluation and corrective actions in case of Performance standar not beeing met.Routines for exercise follow up by SSL is established in revised CMS ” Verifikasjon og logging av Øvelser i Rig Manager CMS 82051.And a new Excel file has been made to to cross check training matrix against drills reported in rig manager.This will make it possible to pinpoint every crewmembers training records for the last 2.5 years

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.02 Measuring and documentation of performance standards to emergency preparedness.

Performance standards for emergency preparedness exercises are not sufficiently measured and documented after exercises. OD use Rig Manager to report and document emergency preparedness exercises. The report templates in the Rig manager are set up for each DSHA scenario that is defined in the Emergency Preparedness Analysis(EPA) for DSY. Each scenario is pre-set with the related performance standards for each step that apply to the exercise. Spot checks in Rig Manager showed that there were several exercise reports where the performance standards were not sufficiently measured and documented.

OD must document that the performance requirements for emergency preparedness are measured and documented to verify that the performance requirements are met.

SS- 17.07.23 Spot checks performed as part of the Vår Energi Rig Intake process and found OK.

SS – 20.02.23 Approved in the OD system

RBV: 24.01.2023 Based on the provided information we will change the criticality from Cat A to Cat C with a new Due date for final closure of Finding 8.01 set to 31st of March. The OMV HSE Coach will follow up to confirm that the implemented measures works

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.03 Handling of Nonconformities

Handling of nonconformities is not performed according to governing and internal requirements. During interviews it became clear that findings from previous rig intake for OMV/PGNiG/Neptune had not been followed up and closed out. OD could not document that:
-nonconformities had been corrected, or recorded in Synergi,
-necessary compensating measures were implemented,
-evaluations for preventing recurrence,

Spot checks were made of following nonconformities:
Procedures related to well control Use of Synergy Systematic mapping of non-ex ignition sources Deviating drills and training Spares for WCS Odfjell had not recorded the deviation/ dispensation in Synergi and could not present a risk assessment related to i.e., emergency release, move off from well centre, use of mooring lines for emergency towing. (Ref. finding 8.40)

The above-mentioned nonconformities are solely spot-checks and Odfjell needs to do a complete review of the current status, record outstanding findings in appropriate system for handling of nonconformities, typically Synergi, or similar.

Odfjell must review their processes regarding.
-recording of nonconformities-implementing mitigating actions when a nonconformity has been identified
-implement measures for preventing the nonconformity to reoccurs

The measures shall be followed up and the effects evaluated.

ÅKP 17.07.23 ref. synergi 229328 All actions are closed related to the follow up.
RBV-27.1.2023:Thank you John Anders we confirm that we will derate the Finding 8.03 and 8.19 from Cat A to Cat C based on provided documentation and action plan described in Synergi Cases 229328 and 229311.Follow up and evaluation of effectiveness of implemented actions should be done on a frequent basis during operations commencing with the Eirik operations i.e. this should be a topic for the regular joint HSE status meetings.

RBV -24.01.2023:Finding 8.03 together with Findings 8.04 and 8.19 will be declassified from Cat A to a Cat C findings upon recieving an action plan addressing what OD will do to improve the process of identifying, recording and handling og Non-conformities, and also to ensure proper identification, reporting and reinstating impaired Technical, Operational & Organizational barriers

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation,-the case regarding CC56 should be reported/recorded in Synergi.

8.04 Barrier Management

The drilling contractor demonstrated lack of awareness of which barriers were established and which function they were intended to fulfil. Reporting of failed or weakened barriers were not performed according to routines, hence the actual barrier status was not correctly reflected. Examples that substantiate the finding: TBAMI (Technical Barrier Against Major Incidents) test of Rig Savers had been recorded as “failed” in the maintenance system IFS. The crew had followed the steps in the job description and the Rig saver had failed to close when the emergency stop button was activated. All 12 rig savers had the same problem and all 12 were reported as “failed” in the maintenance system, the 18th of November 2022. Odfjell could not document that a risk assessment had been performed, or that a Synergi Case had been recorded. The “Barrier dashboard reflected an impaired barrier regarding ignition source control. The alarm delay-time (max, 30s) were adjusted above requirement for several differential pressure transmitters. Some transmitters had alarm delay for 120s. Odfjell could not present a TBAMI job for calibration and testing of the integrity for rooms classified as “safe by ventilation”. Odfjell had not recorded the deviation/ dispensation (DNV class CC 56-wire damage) in Synergi and could not present a risk assessment related to i.e., emergency release, move off from well center, use of mooring lines for emergency towing. The weakened condition of the mooring lines was not treated as an impaired barrier with corresponding mitigating measures. Performance standards for emergency preparedness exercises are not sufficient measured and documented after exercises. Training of emergency teams are not sufficiently recorded and followed up in Rig Manager i.e. there are no measures to explain/elaborate on deviation between planned/scheduled and actually executed Exercises/Drills. Ad. Non-conformances/Deviations identified for L-4 procedures item 4, 5, 6, 8 under Chapter 7.3. Several of these incidents were found closed in Synergi, however several were still found incorrected, and some with wrong/erroneous content related to the procedure. Flame detectors in moonpool were inhibited without recordings in the log (on bridge). Maintenance related to Barrier Elements, Firewater Pumps

Necessary measures to remedy or compensate for missing or impaired barriers could not be documented. Testing and reporting of associated performance requirements is a prerequisite to be able to establish effective barrier management.

Odfjell must ensure that regulatory requirements are met for the barrier management system.

SS – 20.02.23 Closed by OD. Comment a.) in the report regarding “failed” testing of Rigsavers:
The jobs was put in “failed” just to be on the safe side because the instruction seemed to
be incorrect regarding use of Emergency stop. A corrective job was created to follow up
this with engine vendor (Bergen Engines) WO26005963.
Vendor has now confirmed our job description was incorrect and given us the correct
procedure for testing.
Made IFS MMS CASE 5003682 for having this corrected.

RBV: 27.01.2023: Based on provided documentation Finding will be derated from Cat A to Cat C. The effect of the suggested Action plan to be monitored and followed up during operations.

CSV-24-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, Overall OD plan after the PSA audit on DSA.

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.05 GAP analyses new requirements.

OD could at the time of the verification on DSY 15, 16 & 19.12 not present a complete Gap analysis/overview of
compliance with regards to changes in (also new) regulations applicable for DSY. With regards to Well Control Equipment a GAP analyses had been performed against DNV-E-101 and API 53. OD had no plans to map against other relevant standards e.g. Norsok D-010, API 16D etc.

Odfjell to gap all relevant standards to ensure that they have control over new requirements. Risk assessed or implemented important differences since the requirements at design date is required. Odfjell shall have control if any important requirements have been added that could be relevant for Yantai.

RBV: 31.1.2023: OD to present an overview of status of compliance wrt to regulations applicable for DSY, ref. Adept To be followed up

ÅKP: 01.08.2023 Continous process that are managed. Case closed in synergi.

8.06 Working Environment – Shaker/Mud process area

International SOS have performed a verification of chemical exposure in Mud treatment areas on board in October 2022. The report could not be presented for the verification team. As soon as the report is finished a copy should be forwarded to OMV

OD to inform OMV any deviations are revealed.

SS – 20.02.23 Closed in the OD system. ISOS report received.

RBV: 31.1.2023: OD to present latest ISOS report and an action plan for further follow up of Working Environment – Shaker/Mud process area

8.09 ROV unlock of WH connector.

In an emergency situation where the ROV is required for unlocking of the WC connector by a higher pressure than provided by the main system from the rig (i.e., in case of main system failure) may not work due to the design of the actual H4 Wellhead Connector. It should be possible to isolate the primary or secondary chambers by ROV to ensure that one of the circuits can be used if a leak in one of the unlock chambers.

Replumb the connector in a way that primary and secondary unlock chambers can be isolated by a ROV valve to be able to isolate a leaking circuit and still be able to use the ROV on the other circuit.

SS – 31.03.23 Closed. Un-latch of WH connector from ROV will be the third operation (Active pod, Backup pod, ROV). It Is up to the operator to decide and Inform Odfjell If a higher unlock pressure Is required. Then It Is possible to upgrade the system with two ROV valves at operator cost. However, a more complex system will have more leak points and fail sources. Wellesley and DNO considered this finding closed.

SS – 20.02.23 Closed in the OD system

STIM 04.01.23 Un-latch of wellhead connector from ROV will be 3rd operation:

1 Activ POD
2 Backup POD3 ROV

If higher pressure than main system can deliver is required it is likely that both primary and secondary will be needed to un-latch wellhead connector. It is not possible to split primary and secondary and get full functionality with one ROV valve, two ROV valves will be needed. A more complex system will have more leak point and fail sources. Current system is according to applicable standards

30.1.2023

RBV: 31.2023: Further dialog with OD is required to evaluate if a modification of the ROV unlock of WH Connector is required

HEME: 16.1.2023:
The proposed solution is not uncommon and widely used in the industry. The main reason for having such arrangement is due to the fact that pressure from the pods are not sufficient to release the connector. It is true that higher pressure on one chamber may not be enough but at least there will be a possibility to continue trying to release by one chamber through the ROV port if one chamber should fail during the process. In the end the wellhead needs to be cut if all possibilities have failed. Need to conclude if this is a concern and should be covered under continuous improvements

8.10 ROV isolating valve for Accumulator dump.

There is no means to isolate the subsea mounted accumulator dump valve in case this valve starts leaking during operations. The consequence of NOT having this shut of valve will be major downtime and risk to equipment, well and personnel because the well needs to be secured, BOP pulled and repaired before re-running the BOP. A leaking dump valve is not unlikely; hence this safety precaution has been installed on most rigs operating on the NCS, including all other Odfjell rigs. Lack of possibilities to isolate a major leak through this valve may also compromise safety because the well needs to be secured prior to pulling the BOP for repair. Any major leak on the HP/Acoustic dump valves may have considerable effect on being able to use the Acoustic or HP shear bottles during the time from spotting the leak until the well is secured.

Odfjell to install a manual ROV isolation valve after the accumulator dump valves.

SS – 31.03.23 Closed – This would have been a nice feature to have, and It Is possible to do this upgrade. However, due to timing and the implications of doing the upgrade and that it has not been a problem in the past, a decision was made by OMV, Wellesley and DNO to not go ahead with the upgrade.

SS – 20.02.23 Closed in the OD system – Cost estimate for extra isolation valves (Need 2) provided. DNO/Wellesley to approve if continue with this solution.

STIM 04.01.23 This is not safety issue, its a commercial issue.

NORSOK Z-013 not relevant.
This is not specified in contract, but can be implemented at client cost. Owner has declined cost for this modification.

RBV 30.1.2023: Considered closed for OMV since unable to install prior to OMV Eirik well. However, OD to provide Wellesley / DNO with a quote for implementing ROV valves prior to the Wellesley / DNO wells.

Do not fully agree with OD conclusion but it is operator that need to conclude. Most other rigs have installed such valve due to a reason. PSA require continuous improvements for operating on NCS and this is one such improvement because it will (by a leak on the dump valve) prevent pulling the sack that involves danger for personnel and equipment.
A leaking valve will also result in reducing the HP shear bottles to operate as intended during the period the BOP is installed prior to being able to pull to surface. Using the phrase that owner is not willing to take cost may not be a good excuse for documenting that continuous improvement is not taken into account.

CSV-17-01.2023 (Comments in Meeting): OD will provide a quote for the valves and forward the the confirmation to OMV Criticality was reduced from A–>B during the meeting.

8.11 Operational procedures.

Ref. Neptune report related to L-4 procedures item 4, 5, 6, 8 under chapter 7.3. Several were reported updated/corrected and closed in Synergi, however the verification team found that several of these procedures were either not updated, or were updated incorrectly i.e. with wrong content despite recorded as done in Synergi. Using or leaving wrong (non revised) procedures or procedures which have not been quality checked before being made available in the CMS/Rig CMS can lead to impaired Operational Barriers

Odfjell did correct several of these procedures during the verification, but the verification team was not able (time constraints) to verify the updated procedures. Odfjell to doublecheck critical procedures for correct content and details. This is because several faults were detected in the well control related procedures.

SS – 20.02.23 Closed in the OD system

21.01.23 Bjbe Acustic test on stump procedure is updated with correct CMS no and removed text about small capacity in acoustic retur line. BOP close in procedure updated. Removal of accumulated gas in BOP i updated.

RBV-23.01.2023 we agree to change status of Findings # 8.11 (Synergi case # 229337) from Cat. A to Cat. C expecting that OD will present a plan for review and update of other critical (to be defined by OD) L4 procedures with an expected due date. Also OD must update current L4 procedure BOP INNSTENGNINGSINSTRUKS “L4-MODU-DSY-B-WI-607N” to include handling of Nonshearable tubulars e.g BHA/DCs, Corebarrels etc. To be followed up

CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation.

8.18 Temperature rating for line between Manifold and Poorboy.

Odfjell could not verify the temperature requirement of -40C on the line between choke manifold and poorboy degasser. Poorboy has a rating of -46C

Odfjell to reply on design temperature of this line. If not according to requirement a risk assessment to be performed. Alternatively other means to prevent low temperature in the line or make a deviation to the requirement.

SS – 20.02.23 Closed in the OD system. Line is according to DNV-OS-E101 which is the standard OD follows.

STIM 02.01.2023 Request for assistance forward to engineering, awaiting feedback. STIM 03.1.2023 Spec sheet attached, temp rating is -29 to 121C. STIM 10.01.2023. VTC/OMV to inform Odfjell if this is not sufficient.

RBV: 27.1.2023: Can be derated from Cat B to Cat C based on the provided documentation however, the suggested MOC should in fact have been a NC (Non conformance/Deviation) with compensating measures. OD to evaluate and also check if suggested corrective/mitigating measures are correct e.g. using steam hose to increase temperature in line between KC manifold and MGS.

If the -29 C is sufficient for the upcoming operations this should be OK. Operator need to accept and close this item. Consider a deviation against requirement of -40C.

CSV-17-01.2023 (Comments in Meeting): OD to provide a risk assessment and compensating measures. To be forwarded to OMV.

8.19 Use of Synergy

During the verification several previous findings were checked. Many items were closed out in the Synergi system, but during the verification revealed that they had not been closed or closed based on unacceptable reasons/explanations.

Odfjell to consider the way Synergi is used to ensure issues/nonconformities are properly closed out when the action(s) has been verified closed, and NOT when the action is entered in the system. OD to review/revise how Synergi is used by the various Authors to ensure there is a common way of reporting and documenting close out of records/entries.

SS – 17.07.23 Spot checks performed as part of the Vår Energi rig intake and found OK. Considered closed.
SS – 20.02.23 Approved in the OD system

RBV-27.1.2023: Thank you John Anders we confirm that we will derate the Finding 8.03 and 8.19 from Cat A to Cat C based on provided documentation and action plan described in Synergi Cases 229328 and 229311. Follow up and evaluation of effectiveness of implemented actions should be done on a frequent basis during operations commencing with the Eirik operations i.e. this should be a topic for the regular joint HSE status meetings.

RBV -24.01.2023: Finding 8.19 together with Findings 8.03 and 8.04 will be declassified from Cat A to a Cat C findings upon recieving an action plan addressing what OD will do to improve the process of identifying, recording and handling and Non-conformities, and also to ensure proper identification, reporting and reinstating impaired Technical, Operational & Organizational barriers.

8.08 ROV training using hot stab system

No requirements in OD CMS procedures for training of ROV operators to operate Hot Stab system on BOP.

Odfjell presented a new procedure during the verification (ROV training using Hot stab system has been implemented to L4-MODU-DSY-B-PR-312N). Odfjell to ensure that the ROV training is performed even if the procedure has not been implemented in CMS for the upcoming wells. Implementing the training into the ROV company procedure is outstanding and needs to be implemented when the ROV crew is back on the rig.

Henry Meling commented
Closed based on OD confirming that procedures are created

STIM 03.01.23 point 4.19 made in prosedure L4-MODU-DSY-B-PR-312N for ROV training.

ROV personel not on bord at present time, will be informed when they return to rig. Have also made a procedure for how to use flying lead, L4-MODU-DSY-B-WI-610.

Status Completed

8.12 Critical check valves in the BOP control system

There are several critical check valves in the system and if failure in holding pressure the system may not work as intended. No specific PM routine for verifying sealing capability of these valves. At present the test/PM procedures are not according to requirements.

During the verification Odfjell identified critical valves and made procedures for verifying capability. The procedure is a new one that has not been implemented yet but will be tested prior to commencement and when found to be sufficient it will be a part of the Stump test for the Yantai. Odfjell to ensure testing of the valves regularly even if the procedure has not been implemented in the PM system during the upcoming wells.

Henry Meling commented
Closed based on OD reply that IBWM routine is updated and by that the subject valves will be verified prior to first well

​Comments/status STIM 03.01. All valves has been critical evaluated, this has been shown to VTC/ Meling.

Check of critical valves has been implemented in IBWM prosedure.

Status Completed

8.14 Spare parts for WCS

DSY may not have the expected number of spares and Odfjell could not present a critical spare inventory list. Odfjell could not demonstrate that they meet the requirement described in PSA requirements for having performed the classification work as described in Z-008 that also shall lead to spare part selection. According to Odfjell the Yantai have spares based on the OEM proposed spare part items.This finding was also identified during the OMV verification (February 2022):Spare part evaluation.

PSA Activity §46 Classification «The classification shall be used as a basis in choosing maintenance activities and maintenance frequencies, in prioritizing between different maintenance activities and in evaluating the need for spare parts.
Norsok Z-008. Risk based maintenance and consequence classification: chapter 11, Spare Part evaluation

RBV 26.1.2023:  Closed based on provided information​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.15 Verifying acoustic accumulator volume

The method to ensure that the subsea accumulator bottles capacity for the acoustic system is not sufficient to document capacity prior to installing the BOP on a new well as expected in the regulations. The subsea accumulators are more important than the surface accumulators and an alternative mean to check changes in pressure/capacity is to note pressures before and after operation. The subsea mounted HP Shear bottles are tested this way, but the acoustic bottles do not have this check at present and need to be implemented.

Odfjell to implement procedure for checking the capacity of the acoustic accumulators. The remaining pressure shall be above MOP (minimum operating pressure) as defined in API16D/API S53. Odfjell to modify the existing stump test procedure to include note of pressure in the bottles prior to and after having function tested the acoustic functions.

​Comments/status STIM 03.01.2023:Check of pre-charge on IBWM according to NORSOK D-010. No bottles has been removed or added since commencement or other modifications.

Testing regime for DSY is NORSOK D-010. The capacity of acoustic acc. is verified by OEM calculations.

Status Completed
​

Henry Meling commented 16.01.2023:
I would like to go a little further here and ask for the original documentation and calculation results for the acoustic system just to ensure that they are within the requirements in API 16D for such system.

​​CSV-17-01.2023 (Comments in Meeting): OD will update procedure and forward the close-out data/documentation

8.16 Auto-Shear Trigger Valve

Malfunctions have been reported on other rigs related to this actual valve. The Verification Team does not have specific details on the exact reason for failure. Failures mentioned are unintentional activation, and not activating on demand when lifting off the LMRP. Other contractors have replaced this valve design (mechanically operated) with another improved and more reliable design (pilot pressure operated). The trigger is installed and serve as a safety critical purpose, mainly to trigger the casing shear and blind shear when the LMRP is disconnected. It is a backup for the deadman system and by that it is a safety critical valve installed on the BOP. A failure on demand may have big consequences. A critical valve that has proven to fail in the past needs to be improved or exchanged with a new item that has been proven to work according to requirements.

A valve, meeting the requirements for critical equipment, needs to be installed, or a proper risk assessment documenting that the installed valve is according to requirements related to safety, SIL2 and continuous improvement.

​​STIM 04.01.23 PM for inspection and overhaul to be implemented. STIM 11.01.23 IFS CASE made for new 12 mnd PM, CASE nr 130112.

RBV:  30.1.2023:  Closed based on provided documentation​RBV: 27.1.2023: Based on “”last minute”” input/documentation this finding is reclassified as a Cat B finding.  ​OMV will, as a final assurance of the status of the Autoshear trigger valve, require that the trigger valve is dismantled, inspected, witnessed, greased and reinstalled and tested, in addition to the updated PM routines , prior to RTO or subject to running the BOP (ref definition of Cat B findings).  This is required since the valve will not be replaced/upgraded for the OMV operations

RBV-26.1.2023:  Finding declassified from Cat A to Cat C based on provided documentation from OD, however OMV requested to perform an evaluation of the current auto shear trigger valve design to conclude whether the current design is reliable enough​

​OD to forward the new procedure and present the risk assessment performed that describe the concerns with the valve and how the new procedure handle the failure mode experienced on other rigs and how the new procedures prevents such malfunctions to happen on Yantai.

​​CSV-17-01.2023 (Comments in Meeting): OD has made a new PM and possibly risk assessment and forward the close-out data/documentation

8.17 HPHT Seals on Well Control Equipment

Odfjell plan, according to contract, to exchange all seals to the highest possible temperature rating available as required in standards. Odfjell could not verify if they have the correct seals in the K/C stabs between the BOP and the LMRP related to HT.

Odfjell to install seals on the stabs that correspond with the other K/C line system specification related to HT operation. K/C seals for riser on order with +176 Centigrade rating

​RBV: 27.1.2023:  Closed based on provided information.  OMV DSV to verify / confirm update of L4 procedure

8.20 Early Kick detection system

Especially related to HPHT operations a system for early detection of kicks shall be installed. The verification team was unable, based on provided documentation, to confirm that the secondary flow meter system was fulfilling the requirements.

Odfjell to present documentation that proves that the installed system is acceptable as an early kick detection system according to Norsok D-001 section 6.43.3.

​STIM 15.01.2023:  Se vedlagt dokumentasjon for vår Vegapuls sensor, på side 81 ser du angående responstiden (450 ms).
 
Sjekket på flow-teknikk sine sider og der står det at deres corialis har kjapp responstid (til mindre en 0.5sek/ responstid<500ms).
 
​RBV:  27.1.2023:  ​Based on information provided by OD, OMV find that the 2 independent “flow meters” installed on DSY are acceptable for operations on the Eirik wells

8.21 Bypass Loop MGS

A bypass loop on the MGS was not installed at the time of verification, however the verification team was informed that Odfjell was working on a project for installing a new line that will meet the requirements.

Odfjell to present documentation that proves that the installed system is acceptable as an early kick detection system according to Norsok D-001 section 6.43.3.

​Regarding the bypass loop MSG (229346) its 65% finished.
No reported show stopers her.
 
​​RBV:  30.01.2023:  Awaiting confirmation from rig that lines have been physically tested.

​​​CSV-24-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, Estimated to be finished the 25th of January

8.22 Internal Audits of Electrical Installations

Odfjell could not document having performed internal audits regarding electrical installations and systems since DSY started operations in 2019.

Odfjell has a dedicated responsible for electrical system which has the overall responsibility for work practices, safety and integrity of electrical systems.

The responsible person for electrical systems has a scheduled internal audit every 2 years. The rig crew explained that an internal audit was planned early in January 2023. The results from this audit should be forwarded to the rig intake team.

Odfjell should ensure compliance to regulations and perform the bespoken audit in due time before operation starts for OMV.

​Comments/status 06.01.2023 BJES:
Notification for E&I audit sent rig 16.12.2022. Verification will be performed 10-12.01.2023. Based on this action is closed.

Status Completed

​​CSV-27.01.2023: Downgraded to C based on that the audit is performed.

​​CSV-16.01.2023: Finding will be closed when Odfjell submits documentation for completed internal audit.

8.23 Smoke detection-in Accommodation Air Intake

Smoke detectors are not installed in the air intakes for the Accommodation. Ventilation systems for accommodation spaces and control stations shall be arranged in such a way that the penetration into these areas of any flammable, toxic and noxious gases and smoke is prevented.

Smoke detectors shall be installed on all intakes for ventilation air to accommodation spaces.

Odfjell must implement measures to comply with the applicable regulations.

Comments/status 29.12.22 JORG: Smoke detectors are installed inside Air Handling Units for accommodation.

Pictures attached.

811BSFS203-338, 811BSFS203-433, 811BSFS205-334 & 811BSFS205-440

Status Completed

User responsible for action DSY E&I Supervisor” CSV-16.01.2023: Based on the submitted documentation this finding can be closed

8.24 Floodlights towards sea-Lifeboat stations

It was not installed dedicated light sources for illumination of the sea where lifeboats shall be launched.

At the FWD Lifeboat station it was installed 4 floodlights, however these were not directed towards the sea.

AFT Lifeboat station did not have any floodlights towards sea.”

Odfjell must implement measures to comply with the applicable regulations and AoC.

29.12.22 JORG: Both FWD and AFT lifeboat drop zone has four designated floodlight 400W supplied form UPS power. All in good working condition. Drop Zone Floodlight FWD: 866EL006.22-E01 – 866EL006.22-E02 – 866EL006.22-E03 – 866EL006.22-E04 Drop Zone Floodlight AFT: 866EL006.09-E02 – 866EL006.09-E03 – 866EL006.10-E01 – 866EL006.10-E03 Located on railing mezz deck level. (Lower level compared to fwd.) Pictures attached to synergi.
​
CSV-17.01.2023: This finding can be closed based on the submitted documentation.

8.25 System for recording helideck movement

The system for recording movements on the helicopter deck was not connected to a repeater light (light system), which shall be activated when the movements exceed the limitations.
Red flashing lights (repeater lights) around the helicopter deck must be activated automatically when the set limit values for movement are exceeded, identical to the red traffic lights presented on the HMS screen. The repeater light must be visible to the helicopter crew from all directions of approach and when the helicopter is on the helideck and must be dimmable so that it does not dazzle the helicopter crew.

The revised regulation take effect from 01.01.2023. Odfjell must implement the system before operation.

​CSV-17.01.2023: Closed based on KM-Service report-see attachment

8.26 Electrical Safety

Necessary measures had not been taken to avoid dangerous and accident situations related to work in and operation of electrical installations. Several weaknesses related to electrical safety was identified during the offshore survey. Arc-flash energy levels were not available onboard the rig or known by the crew Marking of arc-flash energy levels in the switchboard rooms and electrical distribution boards was not performed. Personnel on board had not completed relevant courses/training related to work in/nearby facilities with high arc flash energy levels. Protection suite for the highest energy levels (PPE 4 Suite) was not available onboard the rig. High Voltage switchboard rooms were not physically locked to avoid unauthorized personnel entering. Safety card for the EIT lead onboard was not updated with the correct permissions. The company responsible person shall issue and control the permissions for all crew members. It could not be documented that safety equipment was part of the maintenance system, and it was not tagged.

Odfjell must ensure that required precautions related to safety when working on electrical systems are met

SS – 20.02.23 Closed in the OD system

​16.01.23 Bsku: Marking labelling of arc-flash energy levels for each of the rigs switchboard are produced and completed

16.01.23 Bsku: Marking labelling of arc-flash energy warning sign description installed in all Switchboard room’s

16.01.23 Bsku: Protection suite for the highest energy levels (PPE 4 Suite) ARC CLOTHING: GORE-TEX PANTS ELECTRIC ARC in order on Rekv. 5007405. Leveringstid ca noen uker, innkjøp arbeider med eksakt dato

16.01.23 Bsku: Odfjell standard, HV  rooms kept open, HV equipment is fully protected against live parts as all HV parts are insulated inside an DNV Approved switchboards quite common solution and used throughout the industry.

16.01.23 Bsku: Access card and registration is controlled by Odfjell Procedure L3-MODU-ALL-TO-PR-018 key factor HV certificate, FSE Nominated person  access control Layout of the rig ( no other equipment in rooms, Switchgear construction completely isolates HV parts, Interlocks. As DSY are in a situation where some crew members will be new, access cards and access register  need to be updated when names in position is defined, however access control and safety for HV system is exactly the same and of high level. New access cards are produced by MODU-TS Senior Engineer Electrical Systems “”Vedlagt finn De oppdaterte adgangskort til HV-romma på Deepsea Yantai.Vennligst sjekk at det stemmer før det utsteder og henger opp listene ved inngongen til HV-romma.
Det blir sjølvsagt ein del endringer på listene framover, men dette skal reflektere dagens status.

22.01.23 Bsku: El. PPE ( Electricians safety equipment ) is part of the maintenance system, inspected on annual basis and performed 3 times, section 442.100.600 in IFS

EL. PPE shall not be tagges as can degrade isolation protection capability, however a register have been  worked out and contain unique location, serial number and all part been inspected ( even IFS job will be generated as normal)

​CSV-26.01.2023: OD will provide a list of and status for personnel that have completed the Unitech-course. It will be emphasized that personnel on board have completed the course. The competence matrix must be updated to reflect this course.

​CSV: 24.01,2023:Arc-flash energy levels were not available onboard the rig or known by the crew Can be closed when OD confirms that all relevant crew members has performed the applicable training. Marking of arc-flash energy levels in the switchboard rooms and electrical distribution boards was not performed. Can be closed based on the submitted documentation Personnel on board had not completed relevant courses/training related to work in/nearby facilities with high arc flash energy levels. Can be closed when OD confirms that all relevant crew members has performed the applicable training. Protection suite for the highest energy levels (PPE 4 Suite) was not available onboard the rig. Can be closed based on the submitted documentation

High Voltage switchboard rooms were not physically locked to avoid unauthorized personnel entering. Can be closed based on the submitted documentation Safety card for the EIT lead onboard was not updated with the correct permissions. The company responsible person shall issue and control the permissions for all crew members. Can be closed based on the submitted documentation It could not be documented that safety equipment was part of the maintenance system, and it was not tagged. Can be closed based on the submitted documentation
​
​CSV-17-01.2023 (Comments in Meeting):Ongoing from OD side

RBV-23.01.2023 OMV agree to derate Finding from Cat A to Cat C based on provided documentation.  A new due date for closure has been set to 28th of February.  OD to provide documentation/confirmation when all issues have been closed. 

8.27 Ventilation Systems

Measures to ensure that there is sufficient overpressure in “safe areas” at all times were insufficiently tested and adhered to. Examples: Fire dampers for air intake to living quarters does not close automatically when registering low-level gas detection. During review of online C&E it was identified that HVAC inlets to accommodation did not shut automatically until “confirmed-gas” (High-level, 30% LEL) was activated. Alarm limits for HVAC were not set in accordance with regulatory requirements. The alarm delay-time (max, 30s) were adjusted above requirement for several differential pressure transmitters. Some transmitters had alarm delay for 120s.Odfjell could not present a TBAMI job for calibration and testing of the integrity for rooms classified as “safe by ventilation”. There were no differential pressure transmitters installed that made it possible to read actual over/under pressure in, for example, living quarters.

The living quarter was equipped with pressure switches, giving a digital signal to K-Safe, OD could not present a calibration job for these switches.”

Odfjell must ensure that areas that are categorised as “safe by ventilation” maintain the integrity at all times and that potential ignition sources are de energized if the integrity is weakened/lost

​Comments/status- A – Fire dampers for living quarters close Automatic according to C&E at confirmed gas Low Level 10%LEL. (Confirmed Gas: Two detectors in Low level or One detector in High level) Print of C&E and F&G performance standard Attached print out of C&E.
– B – KM onboard to update time delay according to regulations. 30 sek.

Update will include all diff press sensors displayed on KM HMI. Attached tag item list.

08.01.23 JORG: WO 26006185 raised to secure history.

KM by Andy Trinh has updated all diff press sensors according to regulations.

All set to 30 sek delay.

Attached KM service report as documentation.

– C – Record of TBAMI jobs and TBAMI performance standard for Diff Pressure Switches attached.
– D – We do not have any pressure transmitters for remote reading of overpressure in living quarter installed on DSY.

Differential pressure switches are installed to monitor overpressure level at 50 pascal. KM

Safety monitor and display these readings.

Located close to Diff Press Switches there is an analogue gauge installed to read actual overpressure.
Attached picture.

​RBV: 28.01.2023 Finding to be closed based on final received documentation
CSV-16.01.2023:

a)Considered to be closed based on the submitted C&E and FDS, and OD’s definition of LOW-level gas and the defined voting principal.
b) Considered to be closed based on the submitted KM service report-See attachment.
c) Needs Clarification-Please forward the TBAMI job – ​CSV-17-01.2023 (Comments in Meeting): Bjarte Fadnes will forward the information.
d) Considered closed based on submitted documentation”

8.29 Systematic Mapping of Ignition sources

Nonconformity from OMV Audit (Feb.2022) – Not Closed

Odfjell could not document to have performed a systematic mapping of non-electric ignition sources (mechanical). In order to fulfil PSA, Facilities regulation section 10a: «In order to prevent and protect against ignition of combustible liquids and explosive gases, a systematic mapping of potential electric and non-electric ignition sources shall be performed. In addition, the necessary technical, operational and organisational measures shall be implemented so as to reduce the risk of ignition as far as possible».

Odfjell explained that the analysis was partly performed, but the offshore part was not done for Deepsea Yantai.”

Odfjell must document that the mapping is performed and that measures are implemented.

​Comments/status “”29.12.22 JORG: Mapping of Non electrical potential ignition sources was performed during yard stay in Okt.22. Inspection used as platform and identification of equipment ID.

KNB 05.01.23: EIT Jørgen holder på å lukke saken i Synergi

08.01.23 JORG:

Attached print of Inspection dashboard for Mapping Of Non Electrical Ignition Sources. 99% finish.
Status Completed

RBV: 30.1.2023:  Still awaiting for some final documentation​

CSV-26.01.2023: There are currently 37 items that have been recorded as “”failed”” in the inspection database. If OD can extract a list of these items and evaluate the criticality for the failed items we will be able to determine the ​extent of required repairs. The jobs must be recorded and documented in IFS.
​​
CSV-24-01.2023 (Comments in Meeting): OD will arrange a teams-session to review the Inspection

​CSV-16.01.2023: Needs clarification – Have all recommendations from the mapping been implemented? What are the remaining issues in Synergi? 

​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.30 Emergency Ex-flashlights

Portable emergency flashlight was not installed in Drilling Control Room, Marine Control room, OIM Office, TSL Office and Engine control room.

These flashlights are to be located in readily accessible places in the control rooms and shall be of a type that is constantly charged and be certified for use in a hazardous area, zone 1.

Install portable flashlight and include in ex register and maintenance system.

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation/pictures
Flashlights have been received onboard, -but not installed?

RBV-20.01.2023:  Finding closed based on received information

8.31 Emergency Stop for Thruster motors

Emergency stop buttons for thrusters are not located in the vicinity of rotating machinery.

Thruster rooms 1–> 6 are equipped with emergency stop buttons, which are located on the VFD Switchboards on Mezz-deck.

Odfjell must ensure that people are not harmed by rotating machinery.

21.02.23 JKAA: Risk assessment updated in Synergi and document is sendt to VTC for review.​ Comments/status

29.12.22 TFYL: Sperringene rundt thruserakslingene er gode nok slik de er. Foreslår å lage et skilt som varsler om roterende utstyr på rekkverket som et tiltak.

KNB 06.01.2023: We have now made large, red warning signs and put them up on the handrails in all Thruster rooms.
Text on sign: “” WARNING – ROTATING MACHINERY – PTW REQUIRED TO ENTER “”. See attachment

Status Completed

CSV-24.01.2023: Findings is considered closed by OMV, based on the submitted risk assessment (see attachment)​CSV-16.01.2023:

Not considered to be closed. The thrusters are already equipped with an emergency stop button which is placed on the VFD switchboard, on mezzanine. However, if the intention with the function is to rapidly to avert threatening situations or limit the impact of dangerous situations that have already occurred, the button on the VFD will not fulfil the function.

The emergency stop device must:

– be easily recognizable, have clearly visible and easily accessible operating devices,

– stop the dangerous process as quickly as possible without resulting in additional risk, The emergency stop function must be available and work at all times regardless of the mode of operation.

The emergency stop devices must supplement other safety measures and not replace them.
https://lovdata.no/dokument/SF/forskrift/2009-05-20-544

​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation/risk assessment/procedure

8.32 Ignition source control

​In addition to findings 8.33 and 8.31 the following items should be followed up:

Outstanding corrective work orders for Ex-equipment should be followed up to ensure that all Ex-equipment have the integrity as per design, -before commencement. The total amount of outstanding corrective jobs were 90, at the time of the audit. Odfjell had engaged personnel from Westcon to finalize these jobs, the goal was that all 90 jobs should be corrected prior to commencement. OMV will follow-up the progress and status. Battery powered hand tools are not recorded and maintained. Tools should be tagged and appropriate maintenance program should be implemented.

Battery-powered equipment that was not of Ex design was deployed in an area where potential sources of ignition were to be removed by gas detection. (Battery powered vacuum cleaner DCR, battery tools in workshop on drill floor. Also applicable for the deck cranes.”

Odfjell must ensure that all corrective work orders for Ex-equipment are finalized and evaluate system for battery powered appliances and tools.

​Some specific facts on  Rig Intake DSY  Finding 8.32/ Synergi Case229331 Ignition source control:
In general we have done annual checks of all portable tools etc as described in Odfjell procedure, register as reflect rig per today, maintained and repaired electrical tools found to need so, labels up all tools after approval from inspection we did, attached a informative performed job, below cut our from IFS system showing annual jobs ( performed as in Historical WO)
EX repair, status as below, some materials expected on 27/1 we will continue with Westcon when we have materials in place.
Awareness use of portable electrical tools ( and under work permit have been noted shall be part of safety meetings)
a)Outstanding Corrective work orders for EX Equipment should be followed up ( Criticality B)…, Odfjell are working with Westcon as we speak to rectify findings from EX inspection, status per today is 21 open low critical Ex repair job reaming, some we are waiting part for from Westcon, informed delivery date 27/01, typically Tag Numbers, EX labels IP washers, so low critical items, Based on this Odfjell believe this comment can be changed criticality on frm B- to C or closed as minor issues

b) Battery Powered hand tool are not recorded and maintained , Not correct as IFS have historical work orders reflecting Odfjell Procedure for annual inspection and re- labelling, example of register Maintenance portable elec. Equipment, this register and equipment I field have been checked out, arranged labelled after inspection and cut out from IFS, Based on this Odfjell believe this comment can be closed

c) Battery Powered equipment found in DCR,   Vacuum Cleaner removed, Based on this Odfjell believe this comment can be closed

Battery Powered tools in workshop on drill floor, workshop not part on EX zone, however use of battery power tool require work permit, Based on this Odfjell believe this comment can be closed

Battery Powered tools in deck cranes are removed, and usage of such only under a valid permit to work ( same as rest of the rig),Based on this Odfjell believe this comment can be closed

​​CSV-25-01.2023: Based on OD’s comments and documentation this finding criticality has been​ reduced from Cat.B–> C. The finding can be closed out when remaining Ex equipment are repaired and signed-out in the maintenance system IFS. 

​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.33 Chiksan on Drill floor

Several Chiksan items were missing ID-number, spot checks were made on drill floor equipment.

OD must ensure that flexible threaded piping systems (Chiksan), are marked maintained and have the correct documentation.

​DSY DSL 22.01.2023 Refreshed color coding on all BX inserts

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

RBV-22.01.2023:  Finding to be closed based on received information

8.34 Calibration of instruments on Cement unit

Pressure gauges on cement unit, was due for calibration April 2021.

OD must ensure that critical drilling instrumentation are maintained and calibrated.

​Martin Decker gauges for pressure are now marked with “”Reference Only”” (See image in attachment)
These gauges are not used for logging and staying on a pressurized unit is not something we practice in Norway.
 
It is standard that the unit is delivered with an MD gauge and map reader in addition to the remote system. Pressure sensors for the remote system are calibrated annually.

​​​RBV-22.01.2023:  Can be closed based on received documentation

CSV-17-01.2023 (Comments in Meeting):OD will forward close-out documentation

8.35 HAZID for manual pipe handling

The Hazid related to manual pipe handling had expired due date for renewal.

HAZID shall be repeated at least every 3 years and in relation to changes that will affect the pipe handling. Document received for Last HAZID related to manual pipe handling was done 05.2019.”

OD must perform new HAZID and update deviation matrix if required. Also ensure that all relevant material handling equipment are covered in the HAZID e.g. drillfloor manipulator arm.

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.36 Maintenance related to Barrier Elements, Firewater Pumps

Acceptance criteria for flow measurements, in the performance standard for main fire pumps, was not recorded during performance testing.

OD must ensure that accept criteria in performance standards for barrier elements, are tested and maintained if required.

SS – 20.02.23 Closed in the OD system
​
Comments/status KNB 03.01.2023:

Regarding Accept criteria and doing the TBAMI jobs strictly according to the Performance

Standard the following can be said:

We have lately had special focus on this and informed crew about the importance of this matter.

As a “positive” result of the above, i.e., the testing of Rig savers (mentioned in VTC report 8.4) was reported as failed because the test procedure could not be followed to the letter with the expected result (even if we suspected errors in the procedure that later proved to be the case).

For the annual TBAMI capacity test jobs for Fire pumps, the test procedure is stated in the Performance Standard document attached to the job.

The performance standard PS-SCE-FG2-03-T for capacity test of fire pumps states the following procedure to verify the capacity: TBAMI test PS-SCE-FG2-03-T:

———————————————————–

“” During this test 2 pumps needs to be running simultaneously.

Open two fire monitors in moon pool, release deluge on drill floor and open adjacent two fire hydrants at the same time.

Check system pressure (min.7 Bar) in one of the hydrants at Heli-deck. “”

———————————————————–

The test is considered “passed” if the measured pressure is minimum 7 Bar, and the corresponding “Route Actions” in the job are then set to “passed” or “failed” depending of result.

I hope this will clarify how the test actually is done and documented. The tests were all set in “passed” during last test (and previous as well.

Upon studying this specific performance standard (and test procedure) we have made a MMS CASE 5003680 to remove the passage “”..then verify/record the capacity on drill floor”” because that belongs a different performance standard (PS-SCE-FG2-05-T TBAMI Function test of deluge nozzles) and may lead to misunderstandings.

Status Completed

CSV-30.01.2022: We need the job-description (TBAMI-Job) to verify that wording complies with the performance standard.​​CSV-17.01.2023: Needs clarification,- Do the descriptions and acceptance criteria in the performance standard match the TBAMI job?

RBV-17.01.2023:  Not possible, based on feedback from Odfjell, to conclude whether the Performance standards are met wrt to Fire Pump capacity, ref. NMA 227, Chapter II Section 6 point 3.   It is also unclear whether the Rig Savers shall close upon activation of the Emergency Stop function or not, or if it is the Test procedure that is wrong.  Especially the latter has not been registered in Synergi and properly case processed , also ref. Management Regulations § 22.​​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, (TBAMI job and Performance Standard)
“

8.37 Follow up on last RBI report findings

Findings from last RBI report October 22, was not treated according to recommendations and no corrective work order had been generated in the maintenance system IFS.

OD must follow up reported findings from the last RBI report

​Comments/status Made jobs in IFS to follow up all findings from RBI 2022. Example: WO26006132 Status Completed

19.01.23 Janm

Two jobs was made to cover the finding on the jockey fire pump’s piping this is WO 26006133 & WO 26006134 these two jobs have been done.Status completed

​CSV-16.01.2023: Normally a finding is not closed out before documentation is provided. Example: Records of completed WO’s

8.38 Maintenance and follow up of loose lifting equipment

Follow up of findings in report after periodic control of loose lifting appliances done by competence of enterprise (CoE) was not properly done. When reviewing the last report after periodic control, done by excess in July 2022, it was revealed that 1 NC (fall arrest block) had not been taken out of service, and 7 RCs regarding Riser Lifting Lugs were missing approved certificates.
Furthermore, 1 RC on pipe handling machine. (Possibility for collision with other equipment) and 1 RC regarding missing certificate for weak link on pipe handling machine were not rectified within 3 months which is the deadline

OD to ensure that findings after periodic control done by CoE are followed up.

SS – Closed according to Synergi 229332
​
04.01.23 YNUL: New fall arrest blocks have been ordered on WO 26006066. Fall arrest block has been recertified and put back in use. RC in Axess/Equip is closed.

Weak link certificate received from Certex. RC in Axess/Equip is closed.

RC on ACS. The Dope application machine has been moved to forward side of HT and the collision danger have been reduced, NOV to be onboard in Feb./March to preprogramme the ACS function. RC in Axess/Equip is closed

21.01.23 JKAA: Certificates for lifting lugs received from vendor, however the certificates refer to API 8C and not NORSOK R-002.

OD has engaged Axess to preform control of documentation from vendor including inspection of these lifting lugs for recertification of the lugs. Due to ongoing rectification of the finding Acess has postponed the date for overdue to

28.02.23: Case to be kept open until we receive certificates of lifting lugs. Axess has this scope. To be follow up by SSL

​​CSV-16.01.2023: All actions are expected to be closed out in Synergi by the 28th Feb.

​RBV:  27.1.2023:  Closed on provided information

​​CSV-17-01.2023 (Comments in Meeting): Ongoing- OD will forward the close-out data/documentation

8.39 Loose lifting equipment – Field survey

Field survey looking at loose lifting equipment revealed several equipment not in accordance with requirements:
Fiber sling on drill floor, not allowed to use according to OD internal requirements Wire sling not marked with yearly color Lifting sling (chain) not marked with yearly color Lifting gear (forerunner for spider and gimble) was not marked with Axess “Tag” Lifting gear for inner bushing not marked with tag. (2-part chain)Lifting subs, ready for use, missing safety pin Storage racks in sack store missing SWL”

OD must make sure that all loose lifting equipment in use are marked and used.

​22.01.23 JKAA: The lifting equipment found on drill floor during inspection was immediately removed from DF.

Lifting gear for inner bushing were discarded and new equipment ordered (are now in place on drill floor, certificate uploaded in synergi certificate nr 579190)

Fiber sling as mentioned were discarded. 2 Wire sling were found without yearly colour and also missing tag, these were also  discarded and 2 new wire sling were ordered. 10m chain sling 15T missing tag was sendt to Certex for control/ recertification and new tag plate mounted by certex. picture of tag plate uploaded in synergi

​​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation

8.40 Storage of loose lifting equipment

Locker room for new loose lifting equipment on mezzanine deck was not properly locked. During field survey it was revealed that an extra rigger loft above the main rigger loft was not locked. This can cause that lifting equipment can be used without required labelling and thus lose control of what is approved or not.

OD must make sure that the rigger loft is locked to ensure loose lifting equipment not in use.

​​CSV-17-01.2023 (Comments in Meeting): OD to provide close-out documentation.RBV-20.1.2023 .  Based on received documentation finding is closed

8.41 Mooring Lines CC 56 – wire damages on all mooring lines

Odfjell had not recorded the deviation/ dispensation in Synergi and could not present a risk assessment related to i.e., emergency release, move off from well center, use of mooring lines for emergency towing.
The damaged wires were “approved” for use in “normal operation”, for 2 wells: the previous “Calypso well”, and the upcoming “Eirik well”.
The weakened condition of the mooring lines was not treated as an impaired barrier with corresponding mitigating measures.
Has Odfjell carried out a risk evaluation where operations/circumstances beyond “”normal operation”” have been evaluated?
In July 2022 it was discovered wire brakes on mooring line #8. OD carried out a thorough survey of all 8 mooring lines by use of a 3rd party company Certex. ISO 4309:2017 for Cranes-Wire ropes- Care and maintenance, inspection, and discard, was used as conformity standard.
The report after the survey showed that none of the mooring lines passed the acceptance criteria set out in ISO-4309:2017.For more details regarding action limitation, see attached Narrative report from DNV.”

Odfjell must present/ document which risk evaluations has been performed related but not limited to:

1. Possible emergency release of the anchor cables to pull the unit away from the well center in the event of a blowout?

2. Anchor line 1 & 8 are dedicated for emergency towing, has this been accounted for?

3. Are well/field specific circumstances included in the evaluation?

4. Are weather conditions, winter weather, included in the evaluation?

ÅP: 17,08,2023 Surevy statement from DNV received and attached

SS-17.07.23. Closed. All damaged mooring wire lines were replaced. DNV to remove the condition of class (CC).
​Synergi 227190 was previously created to follow up this matter and will be open until the rig wires has been changed out. The Synergi created to follow up this finding from OMV (8.41) is proposed to be signed out when Rig Intake team finds the handling of this NC to be handled in accordance with proper handling of Non-Conformities

21.01.23 JKAA: Reply from DnV on CC-56 is attached in this Synergi. As stated in reply from DnV we will preform inspection when unmooring to verify if there is observed further development of thread break. Extended permission of use will be evaluated based on this verification (from DnV). The Mooring analyses for both Calypso and Eirik includes actions towards this CC with restrictions of a pay out owner well center to be maximum 180m, ensuring that all damaged areas is in the wire drum. The understanding of the statement “Normal-Operation” is that the rig is to be moored above one well center. PO286911 is created for 8 new rig wires including 2 spare wires. Change Out of wire is preliminary planned in February in due time before CC61 expires. (if extension permit not given). Synergi 227190 includes Wire damage risk evaluation. Wire damage reply from DV OD Wire Rope Evaluation

RBV ​26.1.2023:  Based on provided information the punch will be derated from Cat A to Cat C with a revised due date of end of Eirik well, where continued use of the damaged wires will be reevaluated.

Ref also the following comments from the VTC Surveyor:

Hei,
Jeg har gjennomgått dokumentasjonen og den ser ok ut. OD har gjort de risikoevalueringene som vi etterspurte, og de har en plan for å følge dette opp. I risikoevalueringen ser jeg at de har brukt kompetent personell som skjønner risikoen og forstår konsekvensene, så det ser bra ut. Det mest ideelle hadde vært å fått skiftet ut alle linene, men med de tiltakene/ forutsetningene som er implementert så tenker jeg vi må kunne si at det er ok for den kommende operasjon for OMV. Det må også legges til grunn at OD har en kontinuerlig fokus på dette gjennom hele kampanjen for OMV.OMV’s boreledere må være klar over situasjonen og kunne stille spørsmål underveis ang. status. (Påse plikten)

9.01 Change out of Rubber Compensators/flexibles

Rubber compensators/flexibles in pipelines are not Tagged or linked to equipment PM when to be replaced. Random change out can result in missing control of these items.

OD should consider change out of these rubber elements in the equipment PM based on criticality.

SS- Odfjell will consider change out of these rubber elements in the equipment PM based on criticality.

9.02 Color coding on BX elevator inserts

Poor/ missing color coding was observed on some of the BX elevator inserts. Odfjell explained that the color coding should be “refreshed” during the ongoing yard stay.

Color coding on BX elevator inserts to be refreshed.

​​DSY DSL 22.01.2023  Refreshed color coding on all BX inserts

9.03 Removal of the check valve on the WH Connector

Due to a requirement from OEM of the HDH4 connector Odfjell plan to remove this check valve. The OEM has a note in the manual saying that the HDH4 connector shall be locked by 3000 psi and then bleed down to 1500 psi. This action will not be possible with the pilot operated check valve installed because the initial 3000 psi has been locked in the system by the check valve. For most wells locking by 1500 psi is sufficient but OEM claim that 3000 psi may be needed for critical operations. The purpose of the installed check valve is to ensure that pressure on the lock side is maintained if the control system is disconnected e.g. by disconnecting the LMRP and the BOP is left on the wellhead. There is no specific requirement for this valve.

Odfjell to present a MOC for removing this valve. The operators need to consider together with Odfjell the need for using a locking pressure higher than 1500 psi and by that removing the check valve. Operator to evaluate expected load on the specific wellhead to be used.

SS- Considered closed by Wellesley and DNO, but needs to be considered on a well-by-well scenario if a higher pressure than 1500 psi is required.

8.28 Inhabitations of Safety Systems

Flame detectors in moonpool were inhibited without being recorded in the override/inhibit-logbook, located on the bridge.

Overrides in the fire and gas system are not automatically restored into normal surveillance after a predetermined time.

Overrides are controlled by the PTW (Permit To Work) system, however, the PTW did not describe that detectors needed to be disabled/inhibited.
Considered to be an impaired barrier.

Odfjell must ensure adherence to procedures /processes.

​17.01.23 NIIC: All crew have been told the importance in logging inhibit sensors on K-safe.
This findings have been filed in TM-Folder which the bridge crew are going through every week.

The CMS procedure are also updated. CMS 94256 and CMS 94257
The PTW system are also asking the CCR when activating the PTW, if there are any sensors which need to be inhibited doing this job.
And also if there are any sensors which need to be activated again after the job is finished and the PTW are getting closed

​RBV: 27.1.2023 Finding confirmed closed based on provided documentation

​​CSV-24-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation, New L4 procedure is made and will be provided

​​CSV-17-01.2023 (Comments in Meeting): OD will forward the close-out data/documentation