| Description |
You have failed to make and give effect to such arrangements for the effective planning, organisation, control, monitoring and review of your preventative and protective measures in that you failed to carry out a suitable and sufficient risk assessment of the integrity of topsides pressure vessels which contain process hydrocarbons.
Your risk-based inspection (RBI) management system has led to a situation where several hydrocarbon-containing topside pressure vessels have not undergone internal inspection since being brought into service, up to 17 years ago in some instances. Internal inspections have been deferred without appropriate risk-based justification being documented, and without reference to recognised industry guidance.
I found during offshore inspection of your Buzzard installation that you could not demonstrate the integrity of vessel V-1500, and you are now conducting significant remedial engineering work, including a Level 3 Fitness for Service assessment, to demonstrate ongoing operational integrity. You were served with an Improvement Notice in 2023 regarding the operational integrity of pressure vessel V-3501 for which you had not conducted an internal inspection.
These two examples highlight that other vessels that have not been internally inspected need to be risk assessed to determine the level of risk to persons on your installations.
Despite enforcement action being taken in relation to V-3501, you did not take a broader review of the associated process failures, neither did you implement adequate corrective actions. This indicates a serious deficiency in your asset integrity management system and a failure to learn from known integrity failings. |
