2 sonja tinnesand - acona
Post on 08-Mar-2016
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CHALLENGES FOR NEW
OPERATORS
- IN COMPLYING WITH PSAS REGULATIONS
Sonja D. Tinnesand, Acona AS
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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MAXIMISING
POTENTIAL
acona.com
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