FINAL IQPC-FPSO Conf LDN-Sept04(Regulatory Supervision) DNV

IQPC FPSO ConferenceLondon 21st and 22nd September 2004London, 21st and 22nd September 2004

REGULATORY SUPERVISION of FPSOs

Division of Responsibilities

REGULATORY SUPERVISION of FPSOs

pand Safety Implications

by Tore Sildnes,

Senior Principal Surveyor,

Off h Cl T h l DNV H d Offi N

IQPC Conference, London, 09-2004

Slide 1

Offshore Class Technology, DNV Head Office, Norway

ContentsContentsContentsContents

FPSO Introduction Relationship between Coastal State AuthoritiesRelationship between Coastal State Authorities,

Maritime Authorities and Class Brief description of Class Systematics Brief description of Class Systematics Local Variations and Practices Implications and Experiences Success Criteria


Slide 2

FPSOFPSO -- HistoryHistoryFPSO FPSO HistoryHistory

FPSO (Fl ti P d ti St d FPSOs (Floating Production, Storage and Offloading units) have developed over the last 40

t b i i l l l tiyears to become increasingly popular solution >100 units in operation worldwide 2/3 of fleet are conversions 70 projects underway70 projects underway 110 projects under study


Slide 3

Growth in the worlds fleet of FPSOsGrowth in the worlds fleet of FPSOsGrowth in the world s fleet of FPSOsGrowth in the world s fleet of FPSOs


Slide 4(Source: Bluewater)

FPSOFPSO -- AdvantagesAdvantagesFPSO FPSO AdvantagesAdvantages

One of the very few feasible technical solutions for the One of the very few feasible technical solutions for the deep and ultra-deep water locationsC ti l l it l dit Comparatively low capital expenditure

Can be built based on conventional shipbuilding technology

Finished and commissioned inshore, thus avoiding costly offshore work.

Can take heavy payloads as well as providing storage and y p y p g goffloading facilities.

Easy offshore installation decommissioning and re-use


Slide 5

Easy offshore installation, decommissioning and re use.

Simple FPSO based on converted tanker


Slide 6FPSO Sendje Berge, Source Bergesen Offshore

Complex PurposeComplex Purpose--built FPSO built FPSO p pp p

d S il N


Slide 7

sgard; Statoil; Norway.

Safety RegimesSafety Regimes -- Jigsaw Puzzle ?Jigsaw Puzzle ?Safety Regimes Safety Regimes Jigsaw Puzzle ?Jigsaw Puzzle ?

Which rules are valid when and for what?Which rules are valid when and for what? National legislation (shelf state) Flag state regulations Flag state regulations Class rules International conventions International conventions

How are these related?


Slide 8

Different Regulatory WorldsDifferent Regulatory WorldsDifferent Regulatory WorldsDifferent Regulatory Worlds

Local (unique) Coastal State Flag state regulations based on Local (unique) Coastal State Regulations

Regional Legislation

Flag state regulations based on international conventions and class g g

Shuttle tanker from Knutsen O.A.S Haewene Brim at Pierce Field for BP.


Slide 9

Shelf State Legislation Shelf State Legislation

FPSOs must comply with Shelf State Legislation of the

S e S a e eg s a oS e S a e eg s a o

p y f g fcountry it is to operateAll states have full sovereignty w.r.t regulating activities on f g y g gtheir continental shelvesActivities on the shelf are generally not regulated byActivities on the shelf are generally not regulated by international conventionsIndustrialised countries are normally well regulated andIndustrialised countries are normally well regulated and have comprehensive rules for activities on the continental shelfshelfThird world countries have only in exceptional cases comprehensive Shelf State Rules for petroleum activities


Slide 10

comprehensive Shelf State Rules for petroleum activities

Shelf State LegislationShelf State Legislationgg

The legislation applies to all activities on the shelf National legislation precede Maritime (Flag State) Rules, g p ( g ) ,

but will normally refer to flag state rules w.r.t. maritime aspectsp

Shelf state rules are normally more comprehensive than flag state rules in that a wider range of aspects are coveredg g p

Approval systematics normally deviates from maritime practisepractise


Slide 11

Flag StatesFlag Statesgg

Shi d M bil Off h U it t di i t ti ll Ships and Mobile Offshore Units trading internationally have to comply with safety regulations of the Maritime A thorit in the co ntr hose flag the nit is fl ing (theAuthority in the country whose flag the unit is flying (the Flag State)

l d d i l h f l i Flag states adopt and implement the safety regulations given in conventions issued by IMO (International

i i O i i )Maritime Organisation) Maritime Safety Regime is a Flag State Regime as the

Flag State is enforcing internationally agreed safety regulations (the conventions) through national maritime


Slide 12law

Flag State Rules and FPSOsFlag State Rules and FPSOsgg

Production/storage units do not need flag but are free to move in international waters when carrying flag

Seaworthiness may be documented by way of maritimeSeaworthiness may be documented by way of maritime certificates issued by Maritime Administrations

Coastal states may require FPSOs to be flagged and l dclassed


Slide 13

International Maritime Organisation (IMO)International Maritime Organisation (IMO)g ( )g ( )

U i d N i b d f i i ff i United Nations body for maritime affairs Develops and maintains conventions giving safety

regulations for ships and MOUs trading internationally

Abt. 156 nations are members of IMO Secretariat and meetings in LondonSecretariat and meetings in London IMO has no operational role


Slide 14

IMO Conventions and ResolutionsIMO Conventions and Resolutions

Important IMO conventions include:o SOLAS (Safety of Life at Sea)o MARPOL (pollution prevention)

L d Lio Load Lineo Tonnageo MODU (Safety code for drilling units)o MODU (Safety code for drilling units)

Degree to which IMO requirements are enforced for FPSOs depend on the flag stateg

Important to check flag authority position early in a project Examples: p

o MARPOL double hull requiremento MARPOL stability requirements


Slide 15

Relations Relations -- Shelf State, Flag & ClassShelf State, Flag & Class, g, g

Flag states require classification Delegation of authority from Flag State to Class is Delegation of authority from Flag State to Class is

normal For operation on continental shel es there are For operation on continental shelves, there are

normally additional local coastal state requirements l i f h i f l h i Delegation of authority from Coastal State Authority

to Class is rare


Slide 16

Relation Maritime Authorities vs ClassRelation Maritime Authorities vs. Class

STATUTORY

National Laws and Regulations

CLASS RULES STATUTORYREGULATIONS

Statutory Services based on delegated

authority

Control by Class Control byA thorities

y

y Authorities


Slide 17

What is Classification ?What is Classification ?

Classification is a system for safeguarding life, property and the environment due to operational consequences

Classification implies a process of verifying unit p p y gstandards against a set of requirements ClassRules and Standards

Classification aims to verify that the required Rule standard is built in, observed and maintainedstandard is built in, observed and maintained throughout the units life


Slide 18

Role of ClassificationRole of Classification

Classification has gained world wide recognition as an adequateClassification has gained world wide recognition as an adequate level of safety and quality, i.e. provides a sound basic safety standard

Classification serves as a verification system for a number of parties who have special interest in the safety and quality of MOUs, such as: National Authorities

I d it Insurance underwriters Owners Building yards and sub-contractorsBuilding yards and sub contractors Finance institutions Charterers


Slide 19

Classification - Lifetime ApproachClassification Lifetime Approach

Design ApprovalDesign Approval

Construction surveyConstruction survey

CertificationCertificationCertificationCertification

Operation followOperation follow--upup


Slide 20

Hierarchy of Classification CertificatesHierarchy of Classification Certificatesyy

DET NORSKE VERITAS

It is hereby certified that Det Norske Veritas h l ifi d h

CLASSCERTIFICATE

has classified the Floating Production, Storage and

Offloading Vessel and that it is built in accordance with the

Societies Rules forOffshore Ships, July 2000

SystemAPPROVAL

DET NORSKE VERITAS

It is hereby certified that Det Norske Veritas has reviewed the NAM F3Concrete Gravity BasePlatform and that it is built in accordance with the SocietiesRules for Fixed OffshoreInstallations, July 1992

DET NORSKE VERITAS


ComponentCERTIFICATES

DET NORSKE VERITAS

It is hereby certified that Det Norske Veritas has reviews the NAM F3Concrete Gravity BasePlatform and that it is built in accordance with the SocietiesRules for Fixed OffshoreInstallations, July 1992

DET NORSKE VERITAS


DET NORSKE VERITAS

It is herby certified that Det Norske Veritas has reviewed the NAM F3Concrete Gravity BasePlatform and that it is built in accordance with the SocietiesRules for Fixed OffshoreInstallations, July 1992

DET NORSKE VERITAS


MaterialCERTIFICATES

DET NORSKE VERITAS


DET NORSKE VERITAS


DET NORSKE VERITAS

It is hereby certified that Det Norske Veritas

DET NORSKE VERITAS


DET NORSKE VERITAS

It is herb certified that Det Norske Veritas has reviews the NAM F3Concrete Gravity BasePlatform and that it is built in accordance with the SocietiesRules for Fixed OffshoreInstallations, July 1992

DET NORSKE VERITAS

It is hereby certified that Det Norske Veritas


Slide 21

has reviewed the NAM F3Concrete Gravity BasePlatform and that it is built in accordance with the SocietiesRules for Fixed OffshoreInstallations, July 1992

has reviewed the NAM F3Concrete Gravity BasePlatform and that it is built in accordance with the SocietiesRules for Fixed OffshoreInstallations, July 1992

Class NotationsClass Notations

Scope of classification is determined by mandatory and additional class notations e gmandatory and additional class notations, e.g.

Main character of class

Service and Type Special feature


Slide 22

of class notationp

notation

FPSO Main Class covers the following systems:

Arrangement incl area classification and escape Arrangement, incl. area classification and escape Emergency safety systems Structural strength including hull and superstructure Structural strength including hull and superstructure,

materials, welding, fabrication and corrosion protection Stability Stability Watertight and weather-tight integrity Machinery and systems for marine use Machinery and systems for marine use Electrical installations for marine use

I t t ti d t ti Instrumentation and automation. Fire protection

P iti k i


Slide 23

Position keeping

Classification - What is not Covered?Classification What is not Covered?

Functionality/reliability of non-safety critical systems Lif ti id ti i t Life time considerations equipment Requirements to user friendlinessq f Requirements to inspection- and maintenance friendliness Requirements to personnel protection only partly


Slide 24

Verification of Requirements - Offshore UnitsVerification of Requirements Offshore Units

Owner, OperatorOwner, Operatore

n

t

s

Flag, Shelf, other

Class

e

q

u

i

r

e

m

R

e

Work Scope


Slide 25

MARPOL and FPSOs: New GuidelinesMARPOL and FPSOs: New Guidelines

SOLASAnnex 1 Unified interpretations

ModifiedMARPOL

L d li

Annex 2

Annex 3 IMO

Modified

Load lines Annex 4

Annex 13. Guidelines for Applicationof Marpol Annex 1. Requirements

to FPSO/FSOsto FPSO/FSOs New


Slide 26

MARPOL and FPSOs: ApplicationMARPOL and FPSOs: Application

Applicable to:Applicable to:

Existing FPSO/FSOs

New built FPSO/FSOs

Conversions from existing tankersConversions from existing tankers

Applicable for units flagged units and for other units where directed by coastal authoritieswhere directed by coastal authorities

Expected entry into force January 2007

Also applicable during temporary disconnection


Slide 27

MARPOL and FPSOs: Impact of ChangesMARPOL and FPSOs: Impact of Changes

Discharge requirements

Double sides / collision riskDouble sides / collision risk

Tank arrangement / sizes

Stability

Enhanced surveysEnhanced surveys


Slide 28

MARPOL and FPSOs: DischargesMARPOL and FPSOs: Discharges

Machinery space drainage Offshore processing drainage Offshore processing drainage Production water discharge Displacement water discharge Contaminated sea water


Slide 29

MARPOL and FPSOs: Discharge classificationg

Prod.from Oil/gas separation

Gas

"wet oil"

wellheadOil/gas separation

Dehydration StorageTransport to

shoreReroute to production

1

shoreproduction stream 2

SeparationGravity

separationGenerators, fuel tanks

and pumps Oil and gas

processing activities

Machinery Open and closed

Seawater introduced into cargo tanks

Contaminated seawater from

ti l

Gravity separation Gravity separationGas flotation

separation

space drainage drainage

Gravity separation

operational purposes

separation

Displacement water discharge

Production water discharge

Offshore processing drainage

Machinery space drainage

Contaminated seawater


Slide 30

MARPOL 73/78 AND NATIONAL REGULATIONS NATIONAL AND REGIONAL REGULATIONS

MARPOL and FPSOs: Means of dischargeMARPOL and FPSOs: Means of discharge

S d h Send ashore Incinerate Separate/discharge Add to production streamAdd to production stream

Di h it iDischarge criteria: Flag state : Marpol: 15 p.p.m. Coastal state: Oslo Paris Convention 40 p.p.m


Slide 31

MARPOL and FPSOs: Collision riskMARPOL and FPSOs: Collision risk

N b ilt FPSO D bl h ll i d Newbuilt FPSOs: Double hull required. (no double bottom).

Converted tankers: Appropriate measurespp pto address collision risk

Existing FPSOs: No upgrade required


Slide 32

MARPOL and FPSOs: Appropriate measuresMARPOL and FPSOs: Appropriate measures

Double sides in way of supply boat area. Ensure that wing tanks in way of supply boat areas are

dedicated ballast tanks or void spaces. Adding sponsoons to the sides of the hull.

F d (Y k h t l f ) i f l Fenders (Yokohama or steel frames) in way of supply boat mooring area.

Use of deck cranes with increased boom length andUse of deck cranes with increased boom length and dynamic positioned supply vessels which maintain sufficient distance from ships sides to avoid contact

Collision avoidance measures (navigational warnings, safety zone etc.)


Slide 33

MARPOL and FPSOs: Limitation of oil outflowMARPOL and FPSOs: Limitation of oil outflow

R i t li bl f t k b t till Requirements applicable for new tankers, but till now not for tankers delivered before 1977.

Maximum oil outflow shall not exceed 30,000 m3 Limits possibilities for location of ballast tanks p Only relevant for VLCC size FPSOs/FSOs


Slide 34

MARPOL and FPSOs: Tank ConfigurationMARPOL and FPSOs: Tank ConfigurationCargo and slop tanks

ll kBallast tanks

29031

Compliant:

1234567Slops

5232

10950 11173 17858 20990 2099015665 1520010950 11173 17858 20990 2099015665 15200

Non- Compliant:

1234567Slops

Non Compliant:


Slide 3536655

Regional RegulationsRegional Regulationsg gg g

Production units may need to comply with regional regulationsregulations

EU-directives apply to FPSOs on continental shelves of member countries and other countries adopting EUmember countries and other countries adopting EU-directives into own legislationOth i l di ti l d di Other regional directives may apply depending on location


Slide 36

Regional Variations & Practices:United KingdomUnited Kingdom

The Duty Holder is responsible for establishing a y p gperformance standard and a verification scheme for the safety critical elements as identified in the Safety Casey y

An independent competent person (ICP) shall execute verification according to the schemeverification according to the scheme

No delegated authority to Flag/Class or requirement for FPSO to be Flagged/ClassedFPSO to be Flagged/Classed

Class covers many safety critical elements for an FPSO, d b d t d t ti l li ithand may be used to document partial compliance with

regulations


Slide 37

EU directives to be complied with

Regional Variations & Practices:NorwayNorway

Permanently placed FPSOs to comply with local y p p ypetroleum regulations referring extensively to local NORSOK standards

Short term FPSOs may alternatively comply with maritime rules (flag and class) for marine aspectsmaritime rules (flag and class) for marine aspects

Operator has overall responsibility for safety objectives and for achieving and maintaining theseand for achieving and maintaining these

No requirement for Flag / Class or delegated authority to th f th P t l Di t tthese from the Petroleum Directorate

EU directives apply for production related aspects


Slide 38

US Gulf of MexicoRegional Variations & Practices:

US Gulf of Mexico MMS has now issued a Final Environmental Impact

Statement giving overall green light for FPSOs in deepwater GoM

USCG states they are ready to take FPSO applications right now (regulatory concerns will be settled)g ( g y )

None operating yet FPSOs on location need not be US flagged (US Customs FPSOs on location need not be US flagged (US Customs

decision March 2001)Sh ttl t k d t b Shuttle tankers need to be :US flagged


Slide 39

Built and crewed from US in compliance with the Jones Act

U S -Gulf of MexicoRegional Variations & Practices:

U.S. Gulf of Mexico Jurisdiction is shared between Mineral Management

Services (MMS) and US Coast Guard (USCG)- ref. MoU (16 Dec. 98)( )

The MMS issue production permit based on - review and audit of production facilities andreview and audit of production facilities and- Certified Verification Agency (CVA) Statement

Th USCG i C ifi f I i (C I ) f The USCG issue Certificate of Inspection (C.o.I.) for floating production facilities; Classification is credited g p ;towards C.o.I.


Slide 40

AustraliaRegional Variations & Practices:

The Duty Holder has overall responsibility for safety

Australia

The Duty Holder has overall responsibility for safety The Federal States in Australia have established a

Safety Case RegimeSafety Case Regime Verification plan to be agreed between the Duty

H ld d th R l tHolder and the Regulator If moving off location, compliance with marine act

incl. marine crew necessary An independent Verification Body shall verify

according to agreement Duty Holder / Regulator


Slide 41

CanadaRegional Variations & Practices:

Two jurisdictions on East Coast:

Canada

Newfoundland; Canada Newfoundland Offshore Petroleum Board (C-NOPB)

Nova Scotia; Canada Nova Scotia Offshore Petroleum Board (C-NSOPB)

P d ti it t Production units must: comply with the Drilling, Installation and Production Regulations

of the respective Boardsof the respective Boards be issued with a Certificate of Fitness from an approved

Certifying AuthorityCertifying Authority In addition all floating units must comply with Transport Canada

Marine Safety Regulations


Slide 42

Marine Safety Regulations

AngolaRegional Variations & Practices:

Angola

No regulations in place for offshore E&P activities Petroleum laws being submitted to Parliamentg All offshore developments are Production Sharing

Agreements where SONANGOL is a stakeholderAgreements where SONANGOL is a stakeholder Operators have used best practice

Cl ifi i d i i l i i ifi Classification and international maritime certificates used as basis

No requirement for flagging/classing units


Slide 43

NigeriaRegional Variations & Practices:

O t ibl t d l i l ti b D t t

Nigeria

Operator responsible towards legislation by Department of Petroleum Resources (DPR)

Present legislation prescriptive including aspects of safety, environment and fiscal revenues

Other agencies that may have involvement in FPSO projects are the Nigerian Maritime Authority (NMA) and Navy

Units must have flag/class documenting satisfactory g g ystructural integrity, and follow mandatory surveys


Slide 44

BrazilRegional Variations & Practices:

HS&E l i l ti i l b t t ff h ifi

Brazil

HS&E legislation in place, but not offshore specific; operational safety legislation under development

Several agencies have jurisdiction: National Petroleum Agency (ANP) Environmental Agency (IBAMA) Coast Guard (DPC)Coast Guard (DPC)

Environmental impact studies requiredCl /fl i i i d f fl i d i Class/flag registration required for floating production facilities


Slide 45

ChinaRegional Variations & Practices:

China Offshore Oil Operation Safety Office (COOOSO) is operating

China

China Offshore Oil Operation Safety Office (COOOSO) is operating unit within China National Offshore Oil Corporation (CNOOC), the only state owned offshore oil & gas companyonly state owned offshore oil & gas company

Rules and regulations established by COOOSO and formally authorised by P.R. China State Bureau of Economy and Tradey y

COOOSO acknowledge some international rules and standards Duty Holder responsible and must obtain certificate of compliance / y p p

fitness from certification agency Certification agency has to be authorised by COOOSO For FPSOs, Rules of major classification societies are accepted


Slide 46

Caspian SeaRegional Variations & Practices:

Caspian Sea

DNV running project with Azeri Safety Authorities and BP-Amoco Exxon Agip and Statoil to develop safetyBP Amoco, Exxon, Agip and Statoil to develop safety regime based on international best practice for offshore E&P activities in Azerbaijanoffshore E&P activities in Azerbaijan

Caspian littoral states do not require international classificationclassification

Foreign operators chose international class to all new d t d fl ti tand converted floating assets


Slide 47

Implications and Experiences: Implementation and Use of Risk AnalysisImplementation and Use of Risk Analysisp yp y

Modern offshore regulations rely heavily on risk analysis Modern offshore regulations rely heavily on risk analysis To be refined during project stages with new requirements often introduced late in

project Few prescriptive requirements

Problems for yards locked into fixed price - no time/money for iterations. Even if yard take precautions, vendors have no role in process, and

additional requirements affecting their supply difficult to enforce without dela s and re orkdelays and rework

On the other hand, risk analyses provide opportunity to circumvent unsuitable prescriptive requirements by demonstrating that alternativeunsuitable prescriptive requirements by demonstrating that alternative solutions have acceptable level of safety.


Slide 48

Implications and Experiences:Process of CommunicationProcess of Communication

Regulator The builder has no channel of

communication with the regulator (e.g. NPD HSE)NPD, HSE) Operator

Traditional triangular

Owner

gcommunication is yard/class/ owner

Shelf State regulations leave a lot of room for interpretations - how

thi b l d h dYard Class

can this be resolved when yard cannot discuss with Regulator ?


Slide 49

Implications and Experiences: Accommodation

Shelf regulations have working environment requirementsenvironment requirements beyond maritime practice, e.g.: lay-outy lighting ergonomic aspects

noise & vibration

Source: Terra Nova project


Slide 50

Implications and Experiences:Working environment regulationsWorking environment regulationsWorking environment regulationsWorking environment regulations

Local working environmental regulations may have strong influence upon the size of the FPSOupon the size of the FPSO

These requirements often introduced late in projects with subcontractors not having any knowledge g y g

No common international standards which cover the area adequately. Main message: a essage:

Must be understood / clarified at early stage of project Require significant investment at design/engineering stage


Slide 51

Implications and Experiences:Conflicting codesConflicting codes

Hull and machinery treated as "marine" with class/flag as basis

Conflicting codesConflicting codes

Hull and machinery treated as marine with class/flag as basis For process systems shelf regulations govern

Utilit d ili t ft f i d Utility and auxiliary systems often common for marine and process systems and thus covered by double set of requirements

T i ll d i i t t i f h t t Typically compressed air, instrument air, fresh water, sea water cooling, etc.

To avoid this cost drivers and re work: To avoid this cost drivers and re-work: detail interpretations with accompanying code and specification

breaks to be made in the project definition phasebreaks to be made in the project definition phase clarifications passed on to sub-contractors and listed in purchase

orders etc


Slide 52

orders etc.

FPSO Experiences: Norwegian Sector Key FindingsNorwegian Sector Key Findings

2002 Study by Norwegian Oil Industry Association on 2002 Study by Norwegian Oil Industry Association on lessons learned from existing Norwegian FPSOs58 fi di d iti l j d i t t 58 findings grouped as critical, major and important

Pls refer http://www.olf.no/lesson/ for detail info

Critical Findings - Project Issues:g j Capex over-runs/Schedule delays

Critical Findings Topside Issues Critical Findings Topside Issues Gas compression liquid carry-over


Slide 53

FPSO Experiences: Norwegian Sector Key FindingsNorwegian Sector Key Findings

Critical Findings Marine Systems: Green Water Hull Cracking Turret Bearing Performance Turret Location

i d d Marine Standards Critical Findings Operations

Layout issues Insufficient accommodationB t lBut also: High Uptime

Good Safety Performance


Slide 54

Good Safety Performance

FPSO Success CriteriaFPSO Success Criteria

Shelf state goal-setting requirements must be turnedShelf state goal setting requirements must be turned into prescriptive verifiable requirements before fixed

i /d li t t t d i tprice/delivery contracts are entered into.

Good collaboration between designer and verifier, including sufficient time allocated for design verification (ref cost of wrong design inconvenience ofverification (ref. cost of wrong design, inconvenience of late verification feed-back, etc.)

Active and professional owner organisation aware of its responsibilities towards shelf authorities.


Slide 55

p

FPSO Success CriteriaFPSO Success Criteria

Understanding and agreeing up front on the responsibilities of risk analyses and the handling of their outcome.

Having adequate resources (competence and manning) to handle the complex piping, electrical and instrumentation installations of an FPSO. M t FPSO j t h ll b b ilt i t diti l hi d th t Most FPSO projects shall be built in traditional shipyards that rely on very efficient fabrication processes. These yards may have up to 50 vessels being constructed each year and anyhave up to 50 vessels being constructed each year and any interruptions in the fabrication schedule can impact on several projects with severe consequences. It is then critical to integrate, as far as possible, with the current yard procedures.


Slide 56

Thank you for your attention. y y

STATOILSTATOIL


Slide 57

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