WE Report

Audits



Odfjell

No person selected

Report No.

5218
Environmental Verification on Deepsea Yantai

Type of audit

Rig Inspections
Odfjell

Auditee/Customer

Odfjell
Wellesley/DNO

Date

2023/04/07

976 days ago

Findings

17
Number of findings

Status

Closed
Rig Inspections


Environmental Verification on Deepsea Yantai
Summary

The verification was carried out to get a better understanding and overview of the processes and work onboard DSY related to chemical-, waste, energy- and barrier management, with special attention on requirements in the Carmen and Norma Discharge permits given by the Norwegian Environmental Agency (NEA). The verification was carried out through interviews of relevant personnel and by exploring the rig and doing spot checks of chemical storage areas, waste stations, diesel consumption and barriers as hose stations, bundling and drain system.

The verification was conducted 19th-21st of April. One (1) non-conformance, four (4) observations, and twelve (12) improvement suggestions were identified during the verification. The findings were presented and discussed in the closure meeting of the verification.

Findings

  • Non-Conformity

    Closed


    Closed


    NC-1: The mud chemical G-Seal was still onboard in sack store after last operation. This chemical is not included in the permits for Carmen/Norma

    In the closing meeting it was agreed to put the tank with G-Seal in quarantine immediately and send the chemical onshore.

    In the closing meeting it was agreed to put the tank with G-Seal in quarantine immediately and send the chemical onshore.
    At a later stage (in 8,5″ section on Carmen) G-seal had to be used, and was after some discussions, taken onboard again.

  • Observation

    Closed


    Closed


    O-1:Undefined and open paper bag with powder content

    Recommend that chemicals are put away and properly stored after use and not be left unattended.

    Informed crews.

  • Observation

    Closed


    Closed


    Deadline was:

    O-2:Unidentified bucket with powder content

    Recommend that chemicals are put away and properly stored after use and not be left unattended

    Informed crews.

  • Observation

    Closed


    Closed


    Deadline was:

    O-3:Chemical list in oil store was not updated, some chemicals were missing in the overview

    Recommends that the chemical overview is updated, and then checked and updated routinely.

    05.06.23 Discussed with DSY Medic who is responsible for risk assessments of all chemicals onboard. Routines to check and update lists are already in place, recurring every 6 months. As for the missing chemicals: Jet-lube HPHT has been added to the list, Castrol High temp grease was already on the list. Physical copy of list in oil store will be checked and updated.

  • Observation

    Closed


    Closed


    Deadline was:

    O-4: Waste bins with oil contaminated mass and rags was overfilled

    As there is a chance that overfilled waste bins could potentially lead to hazardous waste going to sea (affecting marine life) or affecting personnel on board, the Verification Team strongly recommend that waste bins are checked and emptied more often, possibly several times a day depending on the amount of waste generated.

    25.05.2023: This experience will be taken up at the weekly safety meeting at DSY from week 21.
    07.06.2023: included as separate slide in weekly safety meetings and presented to all crews.

  • Improvement

    Closed


    Closed


    IMP-1: The print on the Environmental poster is too small

    Provide 70×100 environemental poster

    Bigger poster will be provided for Norma well
    15.05.23: Poster received and looked good

  • Improvement

    Closed


    Closed


    IMP-2: Poorly placed safety label on Oceanic HW 443 tanks

    The Verification Team recommends that all chemicals should be stored with the safety label in direct sight for the user and that safety labels on all tanks stored in areas where they are exposed to harsh weather should be routinely inspected and changed out when needed.

    05.06.23: Document for experience transfer made. Put into experience transfer folder for all departments on DSY to go through at the beginning of their offshore hitch so all crew will be made aware of this best practice for chemical storage.

  • Improvement

    Closed


    Closed


    IMP-3: Weathered safety label on Houghto-Safe NS 1

    The Verification Team recommends that all chemicals should be stored with the safety label in direct sight for the user and that safety labels on all tanks stored in areas where they are exposed to harsh weather should be routinely inspected and changed out when needed.

    05.06.23: Document for experience transfer made. Put into experience transfer folder for all departments on DSY to go through at the beginning of their offshore hitch so all crew will be made aware of this best practice for chemical storage.

  • Improvement

    Closed


    Closed


    IMP-4: Poorly placed safety label on Musol S

    The Verification Team recommends that all chemicals should be stored with the safety label in direct sight for the user and that safety labels on all tanks stored in areas where they are exposed to harsh weather should be routinely inspected and changed out when needed.

    05.06.23: Document for experience transfer made. Put into experience transfer folder for all departments on DSY to go through at the beginning of their offshore hitch so all crew will be made aware of this best practice for chemical storage.

  • Improvement

    Closed


    Closed


    IMP-5: Disorganised Safety Data Sheets (SDS) in oil store

    It is a requirement that all personnel are familiar with the SDS for each chemical they use. The Verification Team has in conversations revealed that checking SDS before using a chemical is not a common practice for rig personnel. They usually look at safety labels on chemicals to identify risks or they have used the chemical many times and feel they don’t need to read SDS. As a consequence of this attitude, a disorganized SDS system might not be used at all. The Verification Team
    recommends updating the SDS system in the oil store so that users can easily navigate safety precautions and ensure proper risk judgement. Another or additional action could be to add safety labels for each chemical on the front of shelfs where the chemicals are stored.

    30.05.2023 Rearranged SDS folders to a more easy-use folder system and organized oil store on a better way.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-6: The DSY measurement programme (ref. [3]) does not reflect the
    following:
    – Biobar 32 not in Measurement programme
    – Houghto-Safe NS1 used onboard DSY, not part of programme
    – Discrepancy between rig monthly report and measurement
    programme regarding Castrol Hyspin AWH-46
    Information regarding substitution of Vaptreat

    – The Verification Team recommends that information on Biobar 32 and
    usage is implemented in the measurement programme.
    – The Verification Team recommends that Houghto-safe 273-CTF is
    replaced by Houghto-Safe NS1 in the measurement programme.
    – The Verification Team recommends Odfjell to update information
    regarding consumption for Castrol Hyspin AWH-M46. it also could be beneficial to go through Chapter 3
    and review, and update if necessary, all consumption and discharge numbers.
    – The verification team recommends that Odfjell updates the measurement programme correspondingly.

    06.06.23: Received info on status, No updates
    13.06.23: Received Synergi report, disagreement on Biobar 32 to be included in the programme.
    29.08.23: sent argumentation for why Biobar 32 shall be part of the programme.
    12.09.23: Sent additional information regarding regulations, and a guideline on what to be implemented in a measurement programme.
    26.09.23: Review as part of rig intake (Tomcat/PUN) where updated program where asked for as input, but not received.
    06.11.23: Sent a reminder
    08.12.2023: Received the updated Measurement programme.
    29.02.2024: Related to Tomcat AfD we saw that there were wrong information in the programme regarding BOP fluids. The programme was updated immediately and received 29.01.24.

  • Improvement

    Closed


    Closed


    IMP-7: Poorly labelled oil contaminated material and rags waste bins

    The Verification Team recommends that all waste bins are marked and labelled properly. In areas where the waste bins are prone to weathering or any other abrasion, labels should be inspected regularly and improved if needed. This might have to be followed up more regularly in the autumn/winter months as the rig is prone to more harsh weather.

    29.05.23: We have marked the garbage station better. Have placed an order for several labels to better follow up the labeling as they are worn out by weather and wind.

  • Improvement

    Closed


    Closed


    IMP-8: Weathered labelling of dangerous waste on deck

    The Verification Team recommends that all waste bins are marked and labelled properly. In areas where the waste bins are prone to weathering or any other abrasion, labels should be inspected regularly and improved if needed. This might have to be followed up more regularly in the autumn/winter months as the rig is prone to more harsh weather.

    29.05.23: We have marked the garbage station better. Have placed an order for several labels to better follow up the labeling as they are worn out by weather and wind.

  • Improvement

    Closed


    Closed


    IMP-9: Poorly labelled waste with high fire hazard

    The cigarette waste was properly handled as it was stored in a dedicated
    area for safety reasons. However, it is recommended that any time sensitive waste, such as fire hazardous
    waste, should be marked with a time stamp to ensure that it is handled correct.

    29.05.2023: Most everything has been followed (except time stamp), as this is station no. 2 after this has been stored in a metal bucket with a lid first. I will inform about this at the handover and internal HMS meeting that the time for when storage is finished will be stated. Updates the procedure in the same loop.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-10: It is difficult to get a good overview of what the hose reels at the
    hose stations should contain. Placement of labels on hose reels.

    It was discussed under the closing meeting that the labels on the hose stations are hard to change. They are delivered and installed as-is. But in top front of each hose reel there is a plaque/sign hanger ideal for mounting “name plates”. The Verification Team recommend that additional labels shall be installed in front of each hose reel for easier navigation.

    29.05.2023: There are signs on the drums, there is no need for more.
    the verification team respects that.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-11: Personnel exposure to chemical dust due to damaged paper bags

    In the closing meeting the Verification Team was informed that Odfjell
    had contracted International SOS (ISOS) to conduct a dust mapping in June. The Verification Team recommends requesting ISOS to do a review of effects of dust from breaking paper bags, and potentially give advice on mitigating measures.

    06.06.23: Awaiting ISOS getting onboard
    16.08.23: Hav/Land møte DSY. ISOS has never been scheduled out on DSY for a dust survey, only a noise survey. DSY believes that this with dust and handling of chemicals is well taken care of on board via good routines and that the people who work with this use the correct PPE. They therefore wished that this improvement point got closed.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-12: Registered oily content in water from Bilge water separator is much lower than the reported 15 ppm

    DSY has a “Clean” environmental class, but by reporting correct ppm, the rig may be classified as “Clean Design”. This could be beneficial, as operators in rig selection have increasing focus on sustainability and environmental performance. Due to this the Verification Team recommends finding a way to report actual ppm.

    06.06.23: We report according to Flagstate / IMO requirements witch are 15ppm. There is not a a option to rebuild equipment regulated by requirements



Additional Documentation

WE-EA-2023-08_-Environmental-Verification-DSY-April-2023_final.pdf


WE-EA-2023-08_-Environmental-Verification-DSY-April-2023_final.pdf




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Odfjell

No person selected

Report No.

5218
Environmental Verification on Deepsea Yantai

Type of audit

Rig Inspections
Odfjell

Auditee/Customer

Odfjell
Wellesley/DNO

Date

2023/04/07

976 days ago

Findings

17
Number of findings

Status

Closed
Rig Inspections


Environmental Verification on Deepsea Yantai
Summary

The verification was carried out to get a better understanding and overview of the processes and work onboard DSY related to chemical-, waste, energy- and barrier management, with special attention on requirements in the Carmen and Norma Discharge permits given by the Norwegian Environmental Agency (NEA). The verification was carried out through interviews of relevant personnel and by exploring the rig and doing spot checks of chemical storage areas, waste stations, diesel consumption and barriers as hose stations, bundling and drain system.

The verification was conducted 19th-21st of April. One (1) non-conformance, four (4) observations, and twelve (12) improvement suggestions were identified during the verification. The findings were presented and discussed in the closure meeting of the verification.

Findings

  • Non-Conformity

    Closed


    Closed


    NC-1: The mud chemical G-Seal was still onboard in sack store after last operation. This chemical is not included in the permits for Carmen/Norma

    In the closing meeting it was agreed to put the tank with G-Seal in quarantine immediately and send the chemical onshore.

    In the closing meeting it was agreed to put the tank with G-Seal in quarantine immediately and send the chemical onshore.
    At a later stage (in 8,5″ section on Carmen) G-seal had to be used, and was after some discussions, taken onboard again.

  • Observation

    Closed


    Closed


    O-1:Undefined and open paper bag with powder content

    Recommend that chemicals are put away and properly stored after use and not be left unattended.

    Informed crews.

  • Observation

    Closed


    Closed


    Deadline was:

    O-2:Unidentified bucket with powder content

    Recommend that chemicals are put away and properly stored after use and not be left unattended

    Informed crews.

  • Observation

    Closed


    Closed


    Deadline was:

    O-3:Chemical list in oil store was not updated, some chemicals were missing in the overview

    Recommends that the chemical overview is updated, and then checked and updated routinely.

    05.06.23 Discussed with DSY Medic who is responsible for risk assessments of all chemicals onboard. Routines to check and update lists are already in place, recurring every 6 months. As for the missing chemicals: Jet-lube HPHT has been added to the list, Castrol High temp grease was already on the list. Physical copy of list in oil store will be checked and updated.

  • Observation

    Closed


    Closed


    Deadline was:

    O-4: Waste bins with oil contaminated mass and rags was overfilled

    As there is a chance that overfilled waste bins could potentially lead to hazardous waste going to sea (affecting marine life) or affecting personnel on board, the Verification Team strongly recommend that waste bins are checked and emptied more often, possibly several times a day depending on the amount of waste generated.

    25.05.2023: This experience will be taken up at the weekly safety meeting at DSY from week 21.
    07.06.2023: included as separate slide in weekly safety meetings and presented to all crews.

  • Improvement

    Closed


    Closed


    IMP-1: The print on the Environmental poster is too small

    Provide 70×100 environemental poster

    Bigger poster will be provided for Norma well
    15.05.23: Poster received and looked good

  • Improvement

    Closed


    Closed


    IMP-2: Poorly placed safety label on Oceanic HW 443 tanks

    The Verification Team recommends that all chemicals should be stored with the safety label in direct sight for the user and that safety labels on all tanks stored in areas where they are exposed to harsh weather should be routinely inspected and changed out when needed.

    05.06.23: Document for experience transfer made. Put into experience transfer folder for all departments on DSY to go through at the beginning of their offshore hitch so all crew will be made aware of this best practice for chemical storage.

  • Improvement

    Closed


    Closed


    IMP-3: Weathered safety label on Houghto-Safe NS 1

    The Verification Team recommends that all chemicals should be stored with the safety label in direct sight for the user and that safety labels on all tanks stored in areas where they are exposed to harsh weather should be routinely inspected and changed out when needed.

    05.06.23: Document for experience transfer made. Put into experience transfer folder for all departments on DSY to go through at the beginning of their offshore hitch so all crew will be made aware of this best practice for chemical storage.

  • Improvement

    Closed


    Closed


    IMP-4: Poorly placed safety label on Musol S

    The Verification Team recommends that all chemicals should be stored with the safety label in direct sight for the user and that safety labels on all tanks stored in areas where they are exposed to harsh weather should be routinely inspected and changed out when needed.

    05.06.23: Document for experience transfer made. Put into experience transfer folder for all departments on DSY to go through at the beginning of their offshore hitch so all crew will be made aware of this best practice for chemical storage.

  • Improvement

    Closed


    Closed


    IMP-5: Disorganised Safety Data Sheets (SDS) in oil store

    It is a requirement that all personnel are familiar with the SDS for each chemical they use. The Verification Team has in conversations revealed that checking SDS before using a chemical is not a common practice for rig personnel. They usually look at safety labels on chemicals to identify risks or they have used the chemical many times and feel they don’t need to read SDS. As a consequence of this attitude, a disorganized SDS system might not be used at all. The Verification Team
    recommends updating the SDS system in the oil store so that users can easily navigate safety precautions and ensure proper risk judgement. Another or additional action could be to add safety labels for each chemical on the front of shelfs where the chemicals are stored.

    30.05.2023 Rearranged SDS folders to a more easy-use folder system and organized oil store on a better way.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-6: The DSY measurement programme (ref. [3]) does not reflect the
    following:
    – Biobar 32 not in Measurement programme
    – Houghto-Safe NS1 used onboard DSY, not part of programme
    – Discrepancy between rig monthly report and measurement
    programme regarding Castrol Hyspin AWH-46
    Information regarding substitution of Vaptreat

    – The Verification Team recommends that information on Biobar 32 and
    usage is implemented in the measurement programme.
    – The Verification Team recommends that Houghto-safe 273-CTF is
    replaced by Houghto-Safe NS1 in the measurement programme.
    – The Verification Team recommends Odfjell to update information
    regarding consumption for Castrol Hyspin AWH-M46. it also could be beneficial to go through Chapter 3
    and review, and update if necessary, all consumption and discharge numbers.
    – The verification team recommends that Odfjell updates the measurement programme correspondingly.

    06.06.23: Received info on status, No updates
    13.06.23: Received Synergi report, disagreement on Biobar 32 to be included in the programme.
    29.08.23: sent argumentation for why Biobar 32 shall be part of the programme.
    12.09.23: Sent additional information regarding regulations, and a guideline on what to be implemented in a measurement programme.
    26.09.23: Review as part of rig intake (Tomcat/PUN) where updated program where asked for as input, but not received.
    06.11.23: Sent a reminder
    08.12.2023: Received the updated Measurement programme.
    29.02.2024: Related to Tomcat AfD we saw that there were wrong information in the programme regarding BOP fluids. The programme was updated immediately and received 29.01.24.

  • Improvement

    Closed


    Closed


    IMP-7: Poorly labelled oil contaminated material and rags waste bins

    The Verification Team recommends that all waste bins are marked and labelled properly. In areas where the waste bins are prone to weathering or any other abrasion, labels should be inspected regularly and improved if needed. This might have to be followed up more regularly in the autumn/winter months as the rig is prone to more harsh weather.

    29.05.23: We have marked the garbage station better. Have placed an order for several labels to better follow up the labeling as they are worn out by weather and wind.

  • Improvement

    Closed


    Closed


    IMP-8: Weathered labelling of dangerous waste on deck

    The Verification Team recommends that all waste bins are marked and labelled properly. In areas where the waste bins are prone to weathering or any other abrasion, labels should be inspected regularly and improved if needed. This might have to be followed up more regularly in the autumn/winter months as the rig is prone to more harsh weather.

    29.05.23: We have marked the garbage station better. Have placed an order for several labels to better follow up the labeling as they are worn out by weather and wind.

  • Improvement

    Closed


    Closed


    IMP-9: Poorly labelled waste with high fire hazard

    The cigarette waste was properly handled as it was stored in a dedicated
    area for safety reasons. However, it is recommended that any time sensitive waste, such as fire hazardous
    waste, should be marked with a time stamp to ensure that it is handled correct.

    29.05.2023: Most everything has been followed (except time stamp), as this is station no. 2 after this has been stored in a metal bucket with a lid first. I will inform about this at the handover and internal HMS meeting that the time for when storage is finished will be stated. Updates the procedure in the same loop.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-10: It is difficult to get a good overview of what the hose reels at the
    hose stations should contain. Placement of labels on hose reels.

    It was discussed under the closing meeting that the labels on the hose stations are hard to change. They are delivered and installed as-is. But in top front of each hose reel there is a plaque/sign hanger ideal for mounting “name plates”. The Verification Team recommend that additional labels shall be installed in front of each hose reel for easier navigation.

    29.05.2023: There are signs on the drums, there is no need for more.
    the verification team respects that.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-11: Personnel exposure to chemical dust due to damaged paper bags

    In the closing meeting the Verification Team was informed that Odfjell
    had contracted International SOS (ISOS) to conduct a dust mapping in June. The Verification Team recommends requesting ISOS to do a review of effects of dust from breaking paper bags, and potentially give advice on mitigating measures.

    06.06.23: Awaiting ISOS getting onboard
    16.08.23: Hav/Land møte DSY. ISOS has never been scheduled out on DSY for a dust survey, only a noise survey. DSY believes that this with dust and handling of chemicals is well taken care of on board via good routines and that the people who work with this use the correct PPE. They therefore wished that this improvement point got closed.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-12: Registered oily content in water from Bilge water separator is much lower than the reported 15 ppm

    DSY has a “Clean” environmental class, but by reporting correct ppm, the rig may be classified as “Clean Design”. This could be beneficial, as operators in rig selection have increasing focus on sustainability and environmental performance. Due to this the Verification Team recommends finding a way to report actual ppm.

    06.06.23: We report according to Flagstate / IMO requirements witch are 15ppm. There is not a a option to rebuild equipment regulated by requirements



Additional Documentation

WE-EA-2023-08_-Environmental-Verification-DSY-April-2023_final.pdf


WE-EA-2023-08_-Environmental-Verification-DSY-April-2023_final.pdf



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