PTIL/PSA

Seminar -

subsea wellhead fatigue

Monica Ovesen Head of section drilling and well technology

PTIL/PSA

PSA goals

“The Petroleum Safety Authority Norway will set the terms

for and follow up that responsible parties in the petroleum

industry maintain a high level of

health, safety & environment

with particular focus on

emergency preparedness

and thereby also contribute to creating

the highest possible value for society”

PTIL/PSA

Main features of the regulations

Based and functional requirements we expect the industry to perform according to conditions:

Flexibilty to choose viable solutions

Support of organisational strength, roles and responsibilities

Adherence to norms and industry standards that provide predictability for users and indicate the expected level of quality in your operations

To maintain sustainable risk targets and manage your activities in accordance to these

“Tripartiate” collaboration between operators, union representatives and regulators

Promote working conditions based on trust and openness

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Regulatory structure in the HSE area

Framework regulations

(Ministries of labour, environment and health)

Management

regulations Activities regulations Facilities regulations

National legisation in the areas of:

• petroleum operations • the environment • the working environment • health

Guidelines, Recomended

Practices, Standards

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PSA main priorities 2013

MP-B Technical, operational and organisational

barriers

MP-E Preventing acute discharges

MP-GER Groups particularly exposed to risk

MP-M Management and major accident risk

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PTIL/PSA

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Manifold - Separasjon

Singlewell

Multiwell

Subsea facilities

PTIL/PSA

8

Selection of previous experiences

• BP experienced fatigue damage to wellhead West of

Shetland in the 80’ies. Assumption was that VIV caused the

damage

• Norsk Hydro, Oseberg Sør, J-12, August 2005 -

30”Conductor and 20”casing failure after 300 days of drilling

(Relative movement between WH and conductor housing

observed)

• Norsk Hydro, Ormen Lange, A-2, March 2006, 90% fatigue

damage of WH extension after 9 days of drilling

• Norsk Hydro, Fram Øst, B-24, December 2006, WH retrieved

based on exceeded lifetime of 20” weld after 13 days of drilling

(Relative movement between WH and conductor housing

observed)

• Statoil ,Vigdis Ext, F-4 H, April 2007, 30” Conductor failure

after 40 days of drilling (based on analytical work) (Relative

movement between WH and conductor housing observed)

• Statoil , SRI, N-2 H , July 2007 (Relative movement between

WH and conductor housing observed)

ISO 13628-7 Table B.6 Principal parameters

PTIL/PSA

Industry challenges

Requirements of management: - to provide documented and demonstrated compliance with the management regulations with regards to wellhead fatigue

Instrumentation: - to instrument, monitor and record conditions and significant in order to verify the results of analyses, as well as to focus on significant parameters to the extended life of existing facilities

Collection, processing and use of data: -to collect, process and use data inorder to carry out and follow up analyses during various phases of the activities

Loads, load effects and resistance: - to withstand the design loads and probable combinations of these loads at all times

Competency and capacity: - to fulfil expected high level of competence and capacity along with current increase in activity level of the industry

PTIL/PSA

www.psa.no

Questions?

PTIL/PSA

Framework HSE Regulation, Section 10 - Prudent activities

The activities shall be prudent,

• A high level for health, safety and the environment shall be established, maintained and further developed.

Framework HSE Regulation, Section 11 – Risk reduction principles

• Harm or danger of harm to people, the environment or material assets shall be prevented or limited in accordance with the health, safety and environment legislation, including internal requirements and acceptance criteria that are of significance for complying with requirements in this legislation. In addition, the risk shall be further reduced to the extent possible.

Management Regulation, Section 4 – Risk reduction

• In reducing risk as mentioned in Section 11 of the Framework Regulations, the responsible party shall select technical, operational and organisational solutions that reduce the probability that harm, errors and hazard and accident situations occur.

Management Regulation, Section 23 – Continuous improvement

• The responsible party shall continuously improve health, safety and the environment by identifying the processes, activities and products in need of improvement, and implementing necessary improvement measures. The measures shall be followed up and the effects evaluated.

• Applying experience from own and others' activities shall be facilitated in the improvement work.

Framework HSE Regulation

Extract from relevant sections

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Analyses and documentation

Management Regulation, Section 16 – General requirements for analyses

• The responsible party shall ensure that analyses are carried out that provide the necessary basis for making decisions to safeguard health, safety and the environment.

Management Regulation, Section 17 – Risk analyses and emergency preparedness assessments

• The responsible party shall carry out risk analyses that provide a balanced and most comprehensive possible picture of the risk associated with the activities. The analyses shall be appropriate as regards providing support for decisions related to the upcoming operation or phase. Risk analyses shall be carried out to identify and assess contributions to major accident and environmental risk, as well as ascertain the effects various operations and modifications will have on major accident and environmental risk.

Framework HSE Regulation, Section 23 – General requirements for material and information

• The responsible party shall prepare and retain material and information necessary to ensure and document that the activities are planned and carried out in a prudent manner.

• The responsible party shall ensure that documentation demonstrating compliance with requirements stipulated in or pursuant to these regulations, can be provided.

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Barriers and safety functions

Management Regulation, Section 5 – Barriers

• Barriers shall be established that:

• a) reduce the probability of failures and hazard and accident situations developing,

• b) limit possible harm and disadvantages.

• The operator or the party responsible for operation of an offshore or onshore facility, shall stipulate the strategies and principles that form the basis for design, use and maintenance of barriers, so that the barriers‘ function is safeguarded throughout the offshore or onshore facility's life.

Facilities Regulation, Section 8 – Safety functions

• Facilities shall be equipped with necessary safety functions that can at all times

• a) detect abnormal conditions,

• b) prevent abnormal conditions from developing into hazard and accident situations,

• c) limit the damage caused by accidents.

• Requirements shall be stipulated for the performance of safety functions.

• The status of safety functions shall be available in the central control room.

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Facilities Regulation, Design and

loads, Extract from relevant

sections

Facilities Regulation, Section 10 – Installations, systems and equipment

• Installations, systems and equipment shall be designed in the most robust and simple manner possible and such that

• a) the possibility for human error is limited,

• b) they can be operated, tested and maintained without risk to the personnel and with the lowest possible risk of pollution,

• c) they are suitable for use and able to withstand the loads they can be exposed to during operation…

Facilities Regulation, Section 11 – Loads, load effects and resistance

• The loads that can affect facilities or parts of facilities, shall be determined. Accidental loads and natural loads with an annual probability greater than or equal to 1x10-4, shall not result in loss of a main safety function…

• Functional and natural loads shall be combined in the most unfavourable manner.

• Facilities or parts of facilities shall be able to withstand the design loads and probable combinations of these loads at all times…

Facilities Regulation, Section 56 – Load-bearing structures and maritime systems

• Load-bearing structures shall maintain satisfactory safety in use, failure, fatigue and accident limit states. They shall be able to withstand the loads they are exposed to…

• Load-bearing structures shall be sufficiently robust to ensure that local damage or failure will not result in unacceptable consequences.

Facilities Regulation, Section 54 – Christmas tree and wellhead

• Christmas trees and wellheads shall be designed such that prudent recovery, re-entry, well intervention and well control can be carried out.

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Monitoring and use of data

Management Regulation, Section 19 – Collection, processing and use of data

• The responsible party shall ensure that data of significance to health, safety and the environment are collected, processed and used for

• a) monitoring and checking technical, operational and organisational factors,

• b) preparing measurement parameters, indicators and statistics,

• c) carrying out and following up analyses during various phases of the activities,

• d) building generic databases,

• e) implementing remedial and preventive measures, including improvement of systems and equipment.

• Requirements shall be set as regards the quality and validity of the data, based on the relevant need

Facilities Regulation, Section 17 – Instrumentation for monitoring and recording

• Facilities shall be outfitted with instrumentation for monitoring and recording conditions and parameters that can be significant in verifying the results from analyses, as well as parameters of significance to the facility's further use.

• Facilities shall also be outfitted with instrumentation for recording environmental data that can be significant to the petroleum activities. Facilities' instrumentation for flight weather service shall fulfil the requirements in Section 31 of the Civil Aviation Authority's Regulations relating to flight over the continental shelf – commercial aviation to and from the helicopter deck on permanent and mobile offshore facilities, and in the Civil Aviation Authority's Regulations relating to flight weather service.

• The first facility of a new type shall be outfitted with instruments to collect data to verify the calculations. Fixed reference electrodes shall be installed on the first facility in areas where the corrosion conditions differ from areas where experience has been gained.

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Facilities Regulation

Facilities Regulation, Section 48 – Well barriers

• Well barriers shall be designed such that well integrity is ensured and the barrier functions are safeguarded during the well's lifetime.

• Well barriers shall be designed such that unintended well influx and outflow to the external environment is prevented, and such that they do not hinder well activities.

• When a well is temporarily or permanently abandoned, the barriers shall be designed such that they take into account well integrity for the longest period of time the well is expected to be abandoned.

• When plugging wells, it shall be possible to cut the casings without harming the surroundings.

• The well barriers shall be designed such that their performance can be verified.

Activities Regulation, Section 85 – Well barriers

• During drilling and well activities, there shall be tested well barriers with sufficient independence, cf. also Section 48 of the Facilities Regulations.

• If a barrier fails, activities shall not be carried out in the well other than those intended to restore the barrier.

• When handing over wells, the barrier status shall be tested, verified and documented.

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Management regulation, Section 14 – Manning and competence

• The responsible party shall ensure sufficient manning and competence in all phases of the activities, cf. Section 12 of the Framework Regulations….

Activities regulation, Section 21 - Competence • The responsible party shall ensure that the personnel at all times have the

competence necessary to carry out the activities in accordance with the health, safety and environment legislation. In addition, the personnel shall be able to handle hazard and accident situations…

Activities regulation, Section 23 - Training and drills • The responsible party shall ensure that necessary training and necessary

exercises are conducted, so that the personnel are always able to handle operational disturbances and hazard and accident situations in an effective manner.

Competence and capacity

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Openness and trust

• Openness is a prerequisite for the exercise of our supervisory authority

• Norwegian society expects a high degree of openness

• Publication on psa.no

- publication of audit reports, use of instruments, consents, investigation reports and so forth, with the aim of spreading knowledge and experience

- the website receives hits from some 20 000 unique users per month

• Freedom of information - everyone can apply for access to case documents, and Norwegian law sets strict

requirements for what information can be kept confidential

- we received 4 299 freedom of information requests in 2011, of which 160 were refused or approved with restrictions

• Technical seminars organised by us