The Weekly Reflektion Week 22 / 2020
On the 11th November 1976, the Norwegian Petroleum Directorate (NPD) sent a letter to Mobil Exploration Norway Inc (Mobil) that was later claimed to be the most expensive letter ever sent in Norway. The NPD could not accept the design of the Statfjord B platform as an integrated Production, Drilling and Quarters platform. The letter and subsequent discussions resulted in a one-year delay in the Statfjord development.
‘What you don’t have can’t leak’ was the title of Trevor Kletz’s 1978 article on reducing hazards. Similar sentiments can be found in the statement ‘If there is no one there, then no one can get hurt’. These sentiments have become principles associated with inherently safer design. These principles should be applied in every design and modification of a production facility.
The Ekofisk field was discovered in December 1969 and was the first commercial oil field in Norway and the start of the Norwegian hydrocarbon adventure. In 1970 the Norwegian government appointed a commission of inquiry with a mandate to propose regulations for the safety of production and storage facilities and of exploiting petroleum deposits. The work however progressed slowly and did not deliver its report until 12th July 1975. The commission chairman at the time was Nils Vogt from the Norwegian Petroleum Directorate (NPD) who gave his name to the commission and the report. The new safety regulations based on the recommendations from the Vogt Commission report were adopted on 9th July 1976. One provision of the regulations was that the NPD would have the primary responsibility for supervising fixed offshore installations.
The Production and Development Plan for Statfjord had already been approved by the Parliament and the industry was gearing up for building the platforms. The Statfjord A platform was already designed and ready for construction. Statfjord A was a gravity based concrete structure with an integrated production, drilling and quarters topside. The operator of the Statfjord field intended to build a second platform to the same design as Statfjord A. The NPD then considered the Statfjord B design based on the new safety regulations and considered that as far as possible installations should have a separate quarters platform. NPD, in a letter sent to the Statfjord operator (Mobil) on 11th November 1976, said ‘No’ to the proposed Statfjord B design.
The ‘No’ from NPD caused a storm in the industry, shock in the Statfjord licence and received criticism from media, business leaders and politicians. The lack of activities in Norwegian construction yards at the time and the desire to generate employment were major factors in the drive to approve the Statfjord B platform as soon as possible. The Statfjord license were forced to review further concepts for the development including separate drilling, production and quarters platforms. The process resulted in additional project costs and a one-year delay in the Statfjord development. These costs and the lost income from deferred production was estimated to put a price on the letter at NOK 25 million per word.
The design of the Statfjord B platform was eventually agreed with the NPD. While an integrated production, drilling and quarters platform was still by far the most economic concept, the design was changed significantly. The topsides were re-designed to put more space between the quarters and the process and drilling facilities. Improved fire and explosion walls were incorporated into the design and the process facilities were made more to reduce explosion overpressures. The design was more in line with the inherently safer design principles that were later established in the process industry.
The industry claimed at the time that the NPD letter had come as a surprise, however this claim was really not justified since the recommendations from the Vogt report and the subsequent safety regulations were available before the design of Statfjord B, and, in fact, also before the design of Statfjord A. It can be argued that the industry used the ‘beg for forgiveness rather than ask for approval’ principle in seeking consent for the Statfjord B platform. It is to the benefit of the future industry in Norway and credit to the NPD that they stood their ground in delaying the Statfjord development in order to apply inherently safer design principles. Hopefully the industry has learned that these principles are fundamental to the safety of offshore installations and process and chemical facilities.