CHALLENGES FOR NEW

OPERATORS

- IN COMPLYING WITH PSAS REGULATIONS

Sonja D. Tinnesand, Acona AS

ACONA AS - ORGANISATION

CEO

Oddbjrn Kopperstad

Drilling and Well

Technology

Thorleif Totte Lager

HSE & Risk

Svein Olav Drangeid

Incident Coordination

Centre

Vidar Gade

Subsurface and Flow

Technology

Stig Hetlevik

Business Devt & Contracts

Stig Hetlevik

HSE&Q

Rune B. Vik

Corporate Services

Mari Melbye

Finance

Njl Arne Vathne

BACKGROUND

Acona assists both large and small operators: Coordination of applications for consent

Drilling Management projects

Essential to Acona: Give advice to the operators based on understanding of PSAs

practice

The personnel in Drilling Management projects need to know PSAs practice

This presentation shows the issues we emphasize New operators clearly face challenges concerning

understanding and practice

PSAs enforcement as experienced through their evaluations of new operators applying for consent to drill for the first time

LEARNING PSAS ENFORCEMENT

PSA prioritise supervision of new operators starting up drilling activities on the NCS for the first time

Part of their yearly supervision plan

Note that it is on the NCS for the first time

New operators should not underestimate PSAs requirements Size, cost or time span of the operations have no significance

A consent from PSA reflects confidence in the operators ability to perform activities in compliance with requirements

The operator has to convince PSA that the basis for confidence is valid

PSA can not be expected to be more lenient towards new operators or to give them more time rather the contrary

Established operators may supply information and develop actions up to start of drilling ativities new companies should not

LEARNING PSAS ENFORCEMENT

Operator should consider withdrawal of an application for consent to drill if

PSA gives signals that the application is not good enough

PSA stresses requirements / ask for explanations which the company realises that they are not able to fulfill or revert to

in a satisfactory way

LEARNING ORGANISATION AND USE OF CONTRACTORS

All plans presented at pre-qualification have to be fulfilled

Requirements towards operators organisation are comprehensive, especially the see-to-it-duty and follow up Not a question of numbers only Qualifications and experience are as important

Give attention to the planning phase and preparations for drilling not only the result Qualification and follow up of contractors Implementation of own management system Documented criteria for decision

Insufficient management, capacity and competence in the planning phase were reasons behind the PSAs refusal of Premier Oils application for consent, ref letter from PSA 25.06.2010

LEARNING ORGANISATION AND USE OF CONTRACTORS

To be pre-qualified 1 2 persons in drilling and 1 in HSE department are considered sufficient

For planning and exectuion of a drilling operation the organisation has to be strengthened and

extended, especially in drilling

This can be done in three ways

Employing necessary personnel in own organisation

Temporary placement of personnel from mother organisation

Use of contractors for drilling managment

LEARNING ORGANISATION AND USE OF CONTRACTORS

Regardless of solution the number of personnel is not suffcient

Experience / competence counts a lot

If the choice is placement or contractors, the operators own organisation have to be strengthened See-to-it-duty, management systems and follow up

These solutions may be considered a challenge, not a strength for the organisation

LEARNING ORGANISATION AND USE OF CONTRACTORS

Building the organisation should be done as early as possible in the preparation process preferably before detail planning starts

To be able to qualify contractors

Deficiencies in own organisation cannot be solved through use of contractors

on the contrary this will require more internal competence

Using other operators and their competence is regarded likewise

under the regulations they are filling the role as contractor

PSA also considers the total competence of the license group

In the letter to Premier Oil the limited experience of the license is mentioned as part of the reason behind the refusal

LEARNING ORGANISATION AND USE OF CONTRACTORS

In letter of 18.06.2006 PSA states the expectations towards the content of an application for consent to

drill, when using drilling management contractors:

Operators qualification of contractors management system before start of activities. This should cover:

Results of the qualification (the management systems suitability wrt the activities to be performed)

Description of any actions the operator has considered necessary Follow up of these actions

The operators verification program towards contractor during activities

The operators verification program towards own organisation regarding planning of activities

The authorities of operator and contractor in handling of deviations (incl follow up of AoC) and emergency preparedness

management

LEARNING MANAGEMENT SYSTEMS

To comply with requirements for documentation the management system is the main tool

Documenting processes, procedures and decisions necessary to get approval for consent

A fully implemented management system have to be in place when the planning of activities start

PSA will not accept management system being finalized the last weeks before start of drilling activities operators should not accept this from their contractors either

The operators actual use of systems is an issue; PSA expects to see routines, documents and databases being used in the

planning phase

Operator can not use mother companys systems or documents without these being implemented as part of the Norwegian

organisations system All necessary documentation have to be updated and available

when the application for consent is submitted

THE USE OF BEING PRE-QUALIFIED

Pre-qualification = to be approved as either licensee or operator

Being entitled to apply for (part of) production license and / or operatorship

Not entitled to anything else: all applications, approvals etc necessary for an activity have to be

individually substantiated

Requirements for documentation can not be fulfilled in advance they are directed towards specific activities

CHALLENGES - SUMMARISED

Foreign companies:

Understanding the Norwegian administrative practice

Understanding how to act in accordance with a functional legislation

Understanding the see-to-it-duty

All companies:

Acknowledge the importance of management in the planning phase

Implementation of good management systems adapted to the activities

13

MAXIMISING

POTENTIAL

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