| Description |
You have failed to inspect your Closed Drain Drum V3501 for certain deterioration mechanisms (e.g. Microbial Induced) that may lead to a dangerous situation (e.g. loss of primary containment of hazardous liquids and gases as defined within your Safety Case) as you have certain features within the vessel, that you cannot inspect through a non-invasive inspection strategy such as support brackets and a weir plate. Invasive inspection is reasonably practicable and in-line with industry good practice.
Invasive inspections have been deferred on four separate occasions by way of risk assessment, however, these assessments contain insufficient justification (i.e. inspection data) to substantiate moving to a different inspection strategy. You have stated that an invasive inspection will now be undertaken at an opportune point with a non-specified date. This will not allow CNOOC to validate the condition and integrity of the primary containment barrier within the vessel i.e. the corrosion resistant alloy liner, and its continued safe operation. As such these deterioration mechanisms may not be detected and remedied in good time. |
