In 1999 we were informed by Ian Tope, a Risk Engineer working in the HSE department that ESD valves offshore were regularly failing their leak-off tests, or failing to close in the allocated time. Despite this the maintenance records in the computer database (SAP) were reporting that the tests were satisfactory with no fault found.
The valves in question were the oil riser ESDV on Brent Bravo and the Oil and Gas Riser ESDV on Brent Delta which had all failed their mandatory performance tests but no action was taken to remedy this at the time and the maintenance records of the valves were verified by the audit team as being falsified.
This was confirmed under interview with the Asset Manager in September 1999.
Messrs Campbell, Mutimer, and Merry could be cited to give evidence to this fact in a Court of Law
This was confirmed under interview with the General Manager and the Deputy Asset Manager in October 1999.
Messrs Campbell, Mutimer, and Wyatt (the Shell Expro HSE Manager) could be cited to give evidence in a Court of Law.
@ The maintenance records (Work Orders) for XEV 3308/3310 etc with the false recording of a satisfactory test were obtained as record to the facts above from the Brent Maintenance Engineer in Seafield House in September 1999.
@ This is supported by statements from HSE/4 staff, Tope and Hill, the latter being head of the internal verification scheme, the platform inspector R. Galletly, and the DnV independent verification agent (whose evidence confirmed that the leak-off test criteria Brent ESD valves had been raised (unauthorised) by 2000% from 1 standard cubic meter per minute (scm/m) to 20 scm/m.
@ Courtesy of the 1999 PSMR audit documentation all of which could be presented as evidence in a Court of Law
All this was reported to the Oil, Gas and Managing Director by UEFA in a report issued prior to the PSMR Management presentation on 22nd October 1999
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@ Extract from Report from Gerbrand Moyes the Shell Expro Internal Audit Manager to the Oil and Gas Director September 1999
There was evidence of false and misleading information in maintenance records for safety critical equipment, for example the Brent Bravo ESDV which failed its leak-off test in April 1998 was recorded as 'NO FAULT FOUND
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On 22nd October this situation was presented to the full leadership team of enhanced Expro, see following link
In September 2003 immediately after the fatal accident a Technical Integrity Review looked at the testing of ESDVs, in one instance XEV 3308 on Brent Delta, it captured data from 1999 to confirm the data that has already been described at the beginning of this note.
This is important because as you are aware Shell investigation team of Stausholm and Sykes reported they could find no files in Aberdeen related to the 1999 PSMR they had gone missing? - but here is one recorded example of the 2003 team looking back at a valve that was included in the 1999 PSMR findings
@ Mar-1999 - WO10006909 [(1) PL ESD VV XEV-3308 CLOS/LEAK TEST]; History = TRIP CLOSED, CARRIED OUT LEAK TEST SUCCESSFULLY. **
** No closure times recorded thus from SAP unable to confirm that valve meets performance
@ Data courtesy of Technical Integrity Review Team established by Production Director 15th September 2003
The closure time is critical and is information that must be recorded, because it is not recorded leads to the conclusion that the valve failed to meets it closure time criteria, or was not tested.
The evidence speaks for itself.
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Platform |
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Comments @ |
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Brent Alpha |
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BA-XEV-970 leak at 25bar in 5min in 2001 which was in excess of accepted test criteria, Work Order for corrective maintenance cancelled as has the routine to leak off test this valve, other gas riser closure and LOT tests have also been cancelled |
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Brent Bravo |
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Work order signed off as OK when test not carried out, Work order cancelled for corrective work to valve with faults still present on the valve |
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Brent Charlie |
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Maintenance histories for gas riser ESD valves cannot confirm valves meet leak-off test criteria.HP separator ESD valve slow to close but no follow up action, other valve failures not corrected when identified |
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Brent Delta |
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Riser ESDV closure time greater than criteria. Gas riser ESD valve Leak-off test failed due to seal failure. Failed valve not being tested properly but reported as OK for Work Order closure. Corrective maintenance Work Orders cancelled |
@ Data courtesy of Technical Integrity Review Team established by Production Director 15th September 2003
Other examples from elsewhere.
Anasuria is a Floating Production Storage Unit (FPSO). Frigged generally can be interpreted as work carried out prior to the test, i.e. electrical or instrumentation functional override to make the valve operate on demand. Without this pre test work the valve (which by Law should be immediately available in an emergency) would not have functioned.
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Platform |
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Comments @ |
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Anasuria |
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Repeated valve failures - Valve recorded as frigged before test, not tested and left in frigged state after test |
Cormorant A
For some unknown period prior to September 2003 this offshore installation at the hub of the oil export system from the field to Sullom Voe continued to operate with ESD valves that were known to sticking, i.e. not closing at all, or closing with closure times well in excess of mandatory time for closure
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Platform |
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Comments @ |
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Cormorant Alpha |
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Inadequate Maintenance records sticking valves identified during testing. Corrective Work Order raised but not released for remedial actions |
One of the main automatic actuations of an ESD valve is from a signal of fire or gas release from the Fire and Gas safeguarding system. On Dunlin this functionality was not being tested but the routines were being signed off as tested OK or cancelled.
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Platform |
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Comments @ |
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Dunlin |
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F&G inputs to ESD not tested as there are no input inhibits at ESD system, but routines being signed off or cancelled. Tests signed off as successful even when failures noted |
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Platform |
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Comments @ |
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Tern |
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Hudson overpressure protection ESD valve not meeting required performance, known to Asset Manager |
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Platform |
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Comments @ |
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Gannet |
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There are repeated ESD valve failures but Riser ESD valve closure and leak-off test results not in maintenance database |
With similar stories for Fulmar, Shearwater and Nelson.
It should be noted that the purposeful falsification of ESD valve tests is in violation of Shell Codes of Practice (a disciplinary offence) and is likely to be a criminal offence under the various provisions of the Offshore Safety Case Regulations 1992 and the Health and Safety at Work Act.