7. Regulations

06.04.2016
This section describes the relevant laws, rules and regulations in Norway and adjacent continental shelves. Furthermore, the current regulatory framework in Norway has been assessed for the implementation of projects related to unmanned platforms.

Regulations from the following countries have been considered:

  • Norway
  • Denmark
  • United Kingdom
  • The Netherlands
  • Germany

 

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7.1 Overview of Norwegian regulations for the design of UWHPs

Norwegian laws and regulations relevant to offshore activities have immense focus on the safety and health of people and the protection of the environment. Petroleum Safety Authority (PSA) regulations in Norway emphasise on following the same overall principles to manage the risks towards health, safety, environment and the assets, regardless of whether the facilities are manned or unmanned;

  • Facilities shall be based on the most robust and simple solutions as possible (Facility regulation)
  • Prudence and caution in planning and implementation of the activities (Framework HSE regulation / Facility regulation)
  • Use of both technical, operational and organisational barriers (Framework HSE regulation)
  • Application of inherently safer design (Framework HSE regulation)
  • Application of As Low As Reasonably Practicable (ALARP) principle (Framework HSE regulation / Facility regulation)
  • Application of Best Available Technology (BAT) (Framework HSE regulation / Facility regulation)
  • Application of barriers against hazards in the form of detection, prevention, mitigation and emergency response (Management regulation)
  • Provision of independency between barriers (Management regulation)
  • Single failure does not result in unacceptable consequences (Facility regulation)
  • Allocating performance requirements on the barriers and follow-up on the requirements in the operational phase (Facility regulation)

For unmanned facilities, simpler solutions may be chosen provided that these solutions can be proven satisfactory through special assessments, ref. Facility regulation section 6.

Guidelines to the PSA regulations provide references to specific NORSOK and international standards as recognised sources for design methods to meet the requirements in the regulations. The purpose of the guidelines is to demonstrate, how provisions in the regulations can be met; however, the guidelines are not legally binding.

The present NORSOK standards have limited references and prescriptive requirements with respect to the design of unmanned platforms. NORSOK S-001 has some specific requirements related to the design of safety systems for the Normally Not Manned Installation (NNMI), and N-001 has some less strict requirements for Accidental Limit State (ALS) and partial factors for the structural design with conditions as stated in the standard.

The withdrawn NORSOK standard S-DP-001, Rev. 1, December 1994, had two informative annexes; B1 and B2 that covered Type A and Type B of Normally Not Manned Installations (NNMI), but these annexes were removed in Revision 2.

 

7.2 Comparison with other regulations in North Sea area

The purpose of reviewing the offshore legislations from other parts of the North Sea Continental Shelf and performing a comparison with Norway’s offshore legislation was to find out, to which degree they are the same or differ with respect to design and operation of unmanned platforms.

The conclusion from the review is that the Norwegian offshore legislation provides a solid and comprehensive framework for the design and operation of offshore platforms in the Norwegian Continental Shelf (NCS). In its current form, the regulation is significantly less prescriptive than in earlier editions but has extensive prescriptive requirements in its guidelines, which further refer to relevant standards.

If the PSA Facility regulation requirements and the NORSOK “S” series related to technical safety and HSE are used as the starting point for the design of minimum unmanned offshore platforms, the first challenge is to establish, which functions are mandatory on board the minimum unmanned platform, which equipment/barriers can be brought on board during actual visits and which functions can be avoided, if the risks covered by the safety function are not actually present.

The legislation in Denmark, the UK and the Netherlands has more references to the design of unmanned platforms. The Safety Case regime in Denmark and the UK provides the flexibility that duty holders take the responsibility of demonstrating that their plan to develop a field by installing an unmanned platform meets the legislation’s goal-setting requirements.

Table 7-1 indicates the similarities and differences between legislation in Norway and the adjacent continental shelves. Germany does not have any specific offshore regulations and is consequently not included in the table.

 

Table 7-1: Comparison of legislation in Norway and adjacent continental shelves

Table 7-1: Comparison of legislation in Norway and adjacent continental shelves

 

Notes;

  1. Norwegian legislation requires the preparation of a “Plan for Development and Operation” (PDO) of a petroleum deposit. There is a considerable similarity between the documentation for a PDO and a Safety Case, but Norwegian legislation does not lay down a safety case regime
  2. The term used in Norwegian legislation is “simpler facility” with and without “accommodation”
  3. The term used in Danish legislation is “not permanently manned offshore installation”
  4. The term used in UK legislation is “normally unattended installation”
  5. The term used in Dutch legislation is “unmanned mining installation” 6. Norwegian legislation ddoes not exactly use the term ALARP, but it requires that the risk shall be further reduced to the extent possible

By comparing the design requirements for simple unmanned platforms in the withdrawn NORSOK standard S-DP-001 and the Danish Energy Agency's guidelines with the design requirements in the PSA Facility regulation, it might easily be interpreted that UWHP concepts based on minimum and cost-effective solutions will be in non-compliance with parts of the PSA Facility regulation. Nevertheless, the facility regulation section 6 states that simpler solutions may be chosen for such facilities provided that these solutions can be proven satisfactory through special assessments.

The current NORSOK standards also fall short as regards providing any coherent set of minimum requirements for such platforms.

However, in principle, the guidelines and the NORSOK standards are only one way of fulfilling regulations. Alternative solutions may be chosen, provided that the operator can demonstrate that these are safe and fulfil the detailed requirements in the regulations.

 

7.3 Conclusion and recommendations

In Norway, due to the early discovery of several large-sized hydrocarbon deposits in the NCS, manned platforms in the form of large integrated production platforms or complexes were favoured as the most cost-effective concepts for the development of offshore fields for years (e.g. Ekofisk, Statfjord and Troll). Accordingly, the development of regulations adapted the form compatible to such concepts. As a result, the regulations at that time and later updates have had very limited explicit references to the unmanned platforms. The same applies for the development of NORSOK standards. Because of that, the development of any minimum unmanned platforms in Norway quickly gets entangled in the requirements from regulations and standards, which were originally intended for the protection of health, safety, environment and assets on large manned platforms.

To close the gap, the best feasible short-term solution is to develop a guideline or a NORSOK standard that provides an approach to the design of the unmanned platforms for NCS. The approach can either be detailed prescriptive requirements at the level found in the withdrawn NORSOK standard S-DP-001 or according to a risk-based approach, where the burden and the responsibility that the residual risk is ALARP is on the duty holder. Providing that a new standard is developed, the PSA Facility regulation has to be amended accordingly to provide specific references to the new developed NORSOK standard.

More detailed information about regulations can be found in the sub-report, ref. /7/.