0- OLF Recommended Guidelines for the Assessment and Documentation of Service Life Extension of Facilities, Rev 1, 040612

122 – NORWEGIAN OIL AND GAS

RECOMMENDED GUIDELINES

FOR

THE ASSESSMENT AND

DOCUMENTATION OF SERVICE LIFE

EXTENSION OF FACILITIES

Original version

Norwegian Oil and Gas Association recommended guideline for the Assessment and Documentation of Service Life Extension of Facilities

No.:122 Established: 06.06.08 Revision no: 1 Date revised:.04.06.12 Page: 2

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Preface

This guideline has, as well as the new revision, been subject to a review process with Norwegian Oil and Gas Association’s (Norwegian Oil and Gas) member companies, the

Petroleum Safety Authority (PSA) and the Norwegian Petroleum Directorate (NPD). It has subsequently been endorsed by Norwegian Oil and Gas’ Operations Committee, before being

approved by Norwegian Oil and Gas’ director general. The member companies consulted includes: BP, Centrica, ConocoPhillips, Eon, Esso,

PGNIG, Shell, Statoil and Talisman.

The contact person for this guideline and responsible manager in Norwegian Oil and Gas is Manager Operations who can be contacted trough the Norwegian Oil and Gas’ switchboard at +47 51 84 65 00.

The project for developing a guideline on service life extension for aging facilities was

established in the fall of 2006. The first delivery was a Norwegian Oil and Gas’ guideline, describing how to prepare an application for use of facilities beyond their service life. The PSA and the trade unions participated in a reference committee. The first delivery consisted

of Norwegian Oil and Gas’ guidelines 122, NORSOK standards N-006 for Load-bearing structures, Y-002 for Transport systems (pipelines) and U-009 for Subsea Systems, as well as

checklists for Drilling & Well Systems, Risk management, technical safety systems and working environment and Process systems and auxiliary systems.

The three NORSOK standards have been kept unchanged in the first revision, whilst the content from the three checklists has been incorporated into the guideline.

This Norwegian Oil and Gas’ guideline has been prepared with the broad-based participation of interested parties in the Norwegian petroleum industry, and they are owned by the

Norwegian petroleum industry, represented by Norwegian Oil and Gas. Norwegian Oil and Gas is responsible for administration of this guideline.

Norwegian Oil and Gas Association

Vassbotnen 1, Sandnes P.O. Box 8065

4068 Stavanger, Norway Tel.: + 47 51 84 65 00 Fax: + 47 51 84 65 01

Web site: www.norskoljeoggass.no E-mail: [email protected]

http://www.olf.no/PageFiles/574/4%20-%20Drilling%20and%20Well%20systems.pdf

http://www.olf.no/PageFiles/574/4%20-%20Drilling%20and%20Well%20systems.pdf

http://www.norskoljeoggass.no/



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TABLE OF CONTENTS

Table of Contents 1 Objective ............................................................................................................................. 5

2 Abbreviations and definition............................................................................................... 5

3 Highlighting changes in the guideline ................................................................................ 7

4 Introduction ......................................................................................................................... 8

5 Requirements .................................................................................................................... 10

5.1 Life extension period...................................................................................................... 10

6 Definition of operational context ...................................................................................... 12

6.1 Use of the facilities .................................................................................................... 12

6.2 Resource Exploitation ............................................................................................... 13

7 Identification and correction of gaps ................................................................................ 14

7.1 Identification of gaps...................................................................................................... 14

7.2 Correction of gaps .......................................................................................................... 14

8 Life extension assessment ................................................................................................. 16

8.1 Structures........................................................................................................................ 18

8.2 Wells............................................................................................................................... 18

8.3 Drilling systems.............................................................................................................. 19

8.4 Pipelines and subsea ....................................................................................................... 19

8.5 Maintenance ................................................................................................................... 19

8.6 Production Regularity .................................................................................................... 20

9 Risk evaluation.................................................................................................................. 21

9.1 Risk assessment.............................................................................................................. 21

9.2 Emergency preparedness and response .......................................................................... 21

9.3 External environment ..................................................................................................... 21

9.4 Occupational health and working environment ............................................................. 22

9.5 Organizational and human factors.................................................................................. 22

Appendix 1 - Process for application for consents................................................................... 23



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Appendix 2 - Suggested contents list for an application for consent to PSA........................... 26

Appendix 3 - Suggested contents list for an application for consent to NPD .......................... 28

Appendix 4 – Schematic of the application process ................................................................ 29



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1 Objective The objective of this guideline is to give guidance to the process of evaluating and documenting prudent operation and optimum resource exploitation in the life extension of

facilities.

2 Abbreviations and definition Abbreviations:

ALS – Accidental limit state

BAT – Best Available Technology DFI – Design Fabrication Installation

FLS – Fatigue Limit State KLIF - Klima- og Forurensnings Direktoratet LE – Life Extension

NPD – Norwegian Petroleum Directorate P&A – Plug and Abandonment

P&ID – Process and Instrument diagram PDO – Plans for Development and Operation PIO – Plans for Installation and Operation

PSA – Petroleum Safety Authority QRA – Quantitative Risk Analysis

RBI – Risk Based Inspection RCM – Reliability Centred Maintenance ULS – Ultimate Limit State

Definitions:

Aging Process – A process of degradation related to the progression of time and/or the use of the facilities and the systems related to the facilities

ALARP – As Low As Reasonable Practicable, a methodology used for qualitative and quantitative assessment of the risk and risk reduction measures and the benefits of

implementing these. Barrier – Technical, operational and/or organisational elements that individually or together

prevents a specific course of events to occur, or affect events in an intended direction such to limit the damages or losses.

Barrier element – Technical, operational or organisational measures or solutions that are part of realising the barrier function

Barrier function – Purpose or role of a barrier



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Basis regulations – Original design regulations for the facilities or newer design regulations

defined as basis for the integrity of the facilities. Can - Verbal form used for statements of possibility and capability, whether material,

physical or casual.

Deviations - An identified difference between the design, physical and operational condition and company standards/requirements.

Exemption – Denotes the authorities' decision to accept a non-conformity relative to regulatory requirements.

Facilities – Installation, plant and other equipment for petroleum activities. Facilities also comprise subsea installations, pipeline, wells, and cables unless otherwise provided.

Gap - An identified difference between the facilities as-is design and physical condition of the

facilities and the current Facilities Regulations. Life extension - Operation beyond what is stated or assumed in the PDO, PIO or Main

Application

Maintenance management - All activities of the management that determine the maintenance objectives, strategies, and responsibilities and implementation by means such as maintenance planning, maintenance control and supervision, improvements of methods in the organisation

including economic aspects (EN13306).

May - Verbal form used to indicate a course of action permissible within the limits of this Guideline.

Non-conformity – An identified difference between the design, physical and operational condition and/or standard of the facilities and the requirements. (Framework Regulation,

Activity Regulation, Management Regulation and basis design regulation). Safety critical equipment – Equipment that is critical and required if the barrier is to fulfil its

intended function during a hazardous event.

Shall - Verbal form used to indicate requirements to be strictly followed in order to conform to this Guideline, and from which no deviation is permitted unless accepted by all involved parties.

Should - Verbal form used to indicate that, among several possibilities, one is recommended

as particularly suitable (without mentioning or excluding others) or that a certain course of action is preferred, but not necessarily required.



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3 Highlighting changes in the guideline

This guideline has been completely revised. The requirements to methodology and documentation of life extensions have been revised and the application process is moved to an

appendix. The NORSOK standards N-006 for Load-bearing structures, Y-002 for Transport systems (pipelines) and U-009 for Subsea Systems have been kept unchanged in the first revision, whilst the three checklists for Drilling & Well Systems, Risk management, technical

safety systems and working environment and Process systems and auxiliary systems have been incorporated into the guideline.



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4 Introduction Facilities installed on the Norwegian Continental Shelf have consents to operate which are

limited in period based on a number of assumptions that are the basis for the approval of the Plans for Development and Operation (PDO), Plan for Installation and Operation (PIO), main

application or consents to operate. Use of the facilities beyond the consent period requires new consent to operate from the Petroleum Safety Authority (PSA) and the Norwegian Petroleum Directorate (NPD). If facilities are planned to be used beyond design life, means

that the facilities will be life extended.

This guideline is recommended for documenting prudent operations, both for facilities that application for life extension is required and others. The guideline also gives guidelines for development of applications for consents for life extension.

The methodology for evaluating life extension recommended by this guideline has its focus

on the process the Operator needs to go through in order assess whether: - the barriers will fulfil their functions - it is safe to operate

- the facilities effectively exploits the resources in the life extended period.

In the process of evaluating the life extension of facilities, the Operator shall ensure that the following: - compliance with Operators own requirements for life extension, prudent operations

and the requirements in this guideline - management of the barriers throughout the period

- maintain acceptable risk levels throughout the period - acceptable management of aging processes through maintenance management and

management of change

- compliance with the regulations throughout the period

The main steps in the process of evaluating life extension with regard to prudent operation are:

- definition of the operational context - identification of gaps to current Facilities Regulations

- identification of measures to correct gaps - identify condition and qualify barrier elements for life extension - risk evaluations

- documentation of the process



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Figure 1, Example of a process to evaluate life extension seen in connection with the

requirement to apply for consents. It is recommended to have early contact with the Authorities to discuss life extension and

applications for consents.

Finally, the Operator shall, when he has assessed and verified continued operations, apply PSA and NPD for new consents as required.

Chapter 4 outlines the requirements which are the basis for the life extension process as well as the requirement to apply for consents. The remaining chapters’ outline recommendations

for the process required to document that the facilities can operate safely and can ensure efficient exploitation of the resources.



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5 Requirements Consent to continue using facilities during life extension is required by the PSA and the NPD.

The requirements to apply for a consent from the PSA are given in in the Management

Regulations section 25d and the required content of the consent document is described in the Management Regulations section 26. Section 25d state that the application shall be submitted to the PSA one year before the consent period expires. A process for the development of an

application for consent is proposed in Appendix 1. A suggested contents list for development of an application for consent to the PSA is shown in Appendix 2.

The Operator shall ensure involvement of employee representatives in the life extension application process, ref. Framework Regulations section 13.

The requirements to apply for consent from the NPD are given in the Regulations to Act

relating to Petroleum Activity section 30a. The consent is required to ensure that the resource-related terms and preconditions provided in PDOs, PIOs and decommissioning decisions are fulfilled. The application for consent to NPD needs to be submitted, at a minimum, one year

before the consent period expires. This consent application is not necessary if the life extension is based upon an updated PDO / PIO. The NPD has issued a guidance note relating

to life extension within the resource management area (Link). Appendix 3 outlines an example of content for an application of consent to NPD.

Documentation of the assessments and methodologies used to approach the decision to life extend shall be stored and available.

5.1 Life extension period The specified time for when facilities needs to apply for new consent is given based by a number of assumptions that are the basis for the approval of the PDO, PIO, main application

or subsequent consents given by the authorities. If there is no definition of consent period given, the consent period is determined by the shortest design life period.

The period used for the life extension assessments should be based on the long term ambitions of the Operator or production license.

The life extension period that will be granted will be linked to the duration of the production

licence. Consent to operate may be extended by extending the duration of the production licence. It is advised to discuss this with the Authorities.

http://www.npd.no/Global/Engelsk/5-Rules-and-regulations/Guidelines/Samtykke_oppstart_e.pdf



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The requirement for performing gap analysis and life extension assessment and qualification

may upon agreement with PSA, be omitted if the: - period applied for is short - facilities are relatively simple

- facilities are already built in accordance with the current version of the Facilities Regulations

- the application of new consent period is within design life of the facilities. The consent period for pipelines and subsea installations may follow the consent period for

the main platform. In case the design life for the subsea installations is shorter than the main platform, internal evaluations shall be performed to qualify the subsea installations until the

application is made for the main platform (structures or topsides) of the facilities. For separate pipeline transportation systems and subsea fields, separate applications for

consent will be required.

Figure 2 illustrates an example of some of the permissions given for the operation of a facility, design life and the consents required for life extension. For the first new consent period until the end of the licence period, the structures do not need to be qualified for life

extension. When licences have been extended, consent for the life extension in the remaining period can be applied for.



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6 Definition of operational context Life extension analysis and evaluations shall be based on the plans for use of the facilities

during the life extension period.

6.1 Use of the facilities Changes to the operational conditions that can have an impact on the efficiency of resource

exploitation, the risk context and risk picture as well as the performance of the barriers due to ageing, shall be considered.

The potential changes to the operational conditions that influence the degradation of barriers shall be identified and used as basis for life extension evaluations. A drilling and work over

plan for the life extension period as well as future requirements for the platform drilling and work over systems shall be the basis for evaluating the use of the drilling and work over

systems. Based upon experience, the following should amongst others be considered:

- the likelihood of sea bottom subsidence in the case of reservoir depletion - changed environmental conditions and updated methods to calculate loading - the potential changes in fluid compositions, such as an increase in corrosive

components (H2S, CO2, N2), and the potential for micro bacterial activity - the change in the need for intervention, well stimulation and work over

- changes to the original design assumptions - changed in the use of wells, including permanent and temporary abandonment of wells

and waste injection wells

- factors relevant for securing the barrier functions until, and during, permanent plug and abandonment (P&A) activities

- plans for increased gas flow during gas blow down of the gas cap - need for new process or utility equipment due to changed flows, chemistry, pressure,

injection or chemicals

- changed role of the barrier in different operational conditions, and where equipment is taken out of use

- new methodologies to simulate accidental loadings - factors that have an effect on working environment and barrier elements - whether equipment has been taken out of use, e.g. drilling activity has stopped.



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6.2 Resource Exploitation For the application to the NPD, the Operator shall demonstrate that the facilities are well suited for the optimal production of resources and other services to fields that use the

facilities. This shall include how the facilities can be used for third party production, including additional new third party production.

The Operator shall demonstrate that all of the capacity can be used for efficient production and optimal recovery in the period. This should include potential use e.g. artificial lift, water

injection, gas injection, dual completions, etc. The Operator shall identify, and perform a cost benefit analysis of, the alternatives that have

been identified for the future use of the facilities; production of resources, and other services to fields that use the facilities. The cost benefit analysis shall justify the future use of facilities

including operation and maintenance costs. The Operator should provide an assessment of the application of new (to the facilities)

technology and techniques for an increase in production and reserve recovery.

The application to the NPD shall be focused on information about: - changes to conditions in the reservoir (including volumes and rates) - the facilities's flexibility with regards to weight capacity, place availability, well slots

and other relevant capacities - cost development (including operation and maintenance costs)

- supply security, including regularity and vulnerability - orders given by other authorities.

A suggested contents list for an application for consent to the NPD is shown in Appendix 3. Information beyond resource-related factors will only be relevant for the NPD’s consent if it

has a direct impact on resource-related, including cost-related, assumptions.



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7 Identification and correction of gaps The Gaps between the facilities and the current PSA Facilities Regulations shall be identified

and the ALARP process performed during the process of correcting the gaps.

The process to identify gaps is shown in Figure 2.

Figure 2, Process for identification and correction of gaps

7.1 Identification of gaps The gap analysis shall focus on the barrier functions and the factors that influence the barrier elements to perform as required. This includes technical, organizational and operational

elements.

7.2 Correction of gaps

The gaps shall be evaluated in accordance with the ALARP principle. The gaps can be closed through technical, organizational or operational changes, or a combination of these. The evaluation of the gap may also indicate that it may not be worthwhile making any changes

due to the risk and/or cost of implementation.

The identified gaps shall be rated according to the risk of the barriers not being able to fulfil their function. The risk level of gaps shall be evaluated in the context of exemptions and deviations as well as the compensating measures as these may influence the risk.

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This is important in the process of prioritizing the closing of gaps i.e. one must prioritize the

actions required to reduce the risk and prioritize the actions that have the largest effect on reducing the risk level.

The benefits of applying new technology in addressing the gaps shall be evaluated. This could help mitigate or close gaps with less modifications or compensating measures.

Risk assessment is further described in Chapter 8.



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8 Life extension assessment The basis for the design and design life of facilities with its associated platform, wells, subsea

systems and pipelines may be different. When facilities are planned to be used beyond design life, the Operator shall define the life extension period for which the different parts of the

facilities are planned to be used. The Operators’ analyses and evaluations shall demonstrate an understanding of how the time

and aging processes will affect HSE, the facilities barriers including technical operational and organisational aspects and resource exploitation. They shall also identify measures required to

mitigate the impact of the time and aging processes. The processes, resources and methodologies used in the approach to find the “as is” condition

and qualification for life extension shall be documented.

Barrier elements, such as wells, subsea templates, pipelines, risers etc. shall be qualified for the new planned service conditions and life extension. Quantitative analysis shall be used for equipment where known degradation mechanisms are dominating and where models exist to

calculate degradation, remaining margins and prediction of remaining service life. Quantitative analysis is expected for structures, pipelines, position mooring, and flexible or

steel catenary risers etc. Qualification of the other barrier elements for the life extension should be based on a

qualitative assessment, unless a quantitative qualification is feasible.

Figure 2 shows a recommended process for qualitative life extension (LE) assessment.

Figure 2 Recommended life extension assessments of barriers

The status of the known degradation mechanisms applicable for barriers shall be evaluated

and documented.

Barrier condition

Future operating conditions

LE Assessment

Update performance

requirements for the barriers. Need for modifications and

compensating measures Update maintenance and inspection plans

Need for dispensations and exceptions



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Status of the technical condition shall as a minimum include review of:

- design assumptions, dimensioning scenario including changes from original assumptions

- history, findings, reliability

- gaps / deviations / exemptions - technical documentation

- spares availability - “as is” condition.

The basis for acceptance of deviations and exemptions shall be reviewed in relation to the new period. The evaluations of existing exemptions and eventually new compensating

measures shall be documented. The Operator shall review any major damage or defect that may impact the facilities in the

life extension period. Typically this applies to damage or defects where a deviation has been accepted due to a limited period of use or operation and this period has since been changed as

a result of life extension. The Operator is then required to reassess the basis for acceptance to verify that this is still valid for the new period.

Background documentation can be found in: - design basis

- documentation - Process and Instrument Diagrams (P&ID) - Design Fabrication Installation (DFI) resume

- system descriptions - flow diagrams

The history, findings and reliability information can be found in: - production regularity and incident reports (Synergy) and root cause assessments,

- maintenance data and an analysis of maintenance development of costs or hours sufficiently broken down to relevant system or equipment level

- inspection reports or trend reports (corrosion development) - planned and corrective maintenance records - well integrity monitoring history

- on demand test results for safety critical equipment

The effect of degradation on production or other critical systems and equipment can be evaluated as part of demonstrating high production regularity to NPD.

Components with a high consequence in case of failure, which are not available for inspection and where there is no possibility to detect developing failure, shall be identified, analyzed,

and qualified for life extension. It is required that the Operator analyze the consequence in



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case of failure, monitors indications of failure and have plans for compensating actions if

indications of failure is found. Latest knowledge related to degradation and life extension shall be applied, see eg. SINTEF

report A15322 “Ageing and life extension for offshore facilities in general and for specific systems” and NORSOK Y-002, Chapter7.

8.1 Structures Structural analysis shall be performed for qualifying the critical structures and support structures for life extension. The analysis shall follow the principles of NORSOK standard N-

006. Structural analysis of structural designs other than jacket structures shall follow the principles outlined in N-006.

The selection of the structural parts that require being qualified for life extension may be based on the consequence of failure, the updated design loading due to changed operating

conditions and the environmental loads. Structures that may be found critical for life extension are, but not limited to, the main bearing structures including parts of the main deck,

piles with connection to the main structure, mooring systems, flare tower, the drillfloor and support structure, drilling derrick, the helicopter deck and well conductors.

It is expected that the evaluation shall cover all relevant design limit states (ULS, FLS and ALS).

Re-qualification of structures to a different design standard than used in the original design shall include a gap assessment of the applied fabrication and manufacturing at construction

compared to the standard used together with the applied design standard.

Structural components with a high consequence of failure which are not available for inspection, and where there is no possibility to detect developing failure, shall be analyzed and qualified for life extension, e.g. for piles and pile grouting, buried anchors and anchor

chains. The actions required to ensure that the structure will fulfill its function during the life extension shall be described.

The need for independent verification of the analysis of the load bearing structure shall be considered.

8.2 Wells

A review of the barriers for the wells based on the future plans shall be carried out. This review must identify required actions to ensure that the technical, operational and

organizational aspects related to barriers are acceptable for the life extension.



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The review shall be based on the standards and best practices used for well integrity. The

actions required to ensure that these barriers fulfill their functions during the life extension shall be described.

The wells with description of the well integrity monitoring system shall be described. The well integrity of all wells shall be documented including waste injection wells and temporary

abandoned wells. A plan for how the well integrity is secured for the future use of wells (ref. NORSOK D-010) including potential delayed P&A shall be developed. Any special requirement for well control as well as killing capabilities for ageing wells shall be considered

and described.

Subsea wellheads shall be analyzed for potential loading including, if it is found to be critical, their effect on wellhead fatigue during life extension.

8.3 Drilling systems

The drilling systems shall be evaluated for operational conditions during life extension to assess whether the systems can manage to fulfill their role and operate safely during the

period of life extension.

8.4 Pipelines and subsea An analysis and assessment shall be carried out to demonstrate the remaining service life for

the pipeline and subsea systems and their potential for use beyond the original design life. The following standards are recommended:

- NORSOK Y-002 “Transport Systems” - NORSOK U-009 “Subsea Systems”.

In the case where current standards are used for re-qualification, and with the possibility to utilize more of the materials, it should be noted that the contribution to the safety level may

have shifted between e.g. fabrication vs. design. Re-qualification of a system toward an updated fabrication standard addressing only a part of an updated industry standard may be non-conservative.

Re-qualification of a component to a different design standard than used during original

design shall include an assessment of the applied fabrication and manufacturing at construction compared to the standard used together with the applied design standard.

8.5 Maintenance Consequences may change for an ageing facility due to increased probability of:



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- simultaneous failures

- subsequent failures - failures in consequence reducing barriers.

A review of the maintenance management systems shall be carried out to determine status and how the ageing processes is covered in the maintenance program. The review shall evaluate

the need for updating the reliability, vulnerability and consequence analysis where these are used as basis for the maintenance system. Experience from failures shall also be part of the evaluation.

8.6 Production Regularity A review of the critical systems and equipment for securing high availability shall be

performed is this is required for the Operator or the Authorities.



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9 Risk evaluation Assessments shall be performed to verify that the facilities’s risk level is within acceptable

limits in the period of life extension. The following risk evaluations shall be performed based on the context defined for life

extension: • Risk assessment of major accident risk, Quantitative Risk Analysis (QRA) • Emergency preparedness and response

• External environment • Occupational safety, health and working environment

9.1 Risk assessment

A risk assessment, e.g. QRA shall be performed, documenting the facilities major accident risk level for the period of life extension. The risks shall be evaluated with regards to the

Operator’s acceptance criteria, and criteria given in current version of Facilities Regulations section 5 regarding barrier status.

It is expected that the latest available technology and knowledge related to analysis of major accidents is applied, including check of the validity of “hidden” assumptions, ref. NORSOK Z-013.

The accidental loads with assumptions shall be based upon latest available knowledge and

technology. It shall further be checked that the explosion and fire walls and equipment such as piping and pipe supports are able to withstand fire and explosion loads.

The assumptions made in risk assessments shall be evaluated for the assumed operation during the period of life extension. The vulnerability, actual and expected effectiveness of the

barrier function, including technical, organizational and operational elements shall be included in the risk assessment.

9.2 Emergency preparedness and response

A review of the current emergency response systems shall be performed, including an evaluation of how operational changes and new requirements will be met in the period of life extension. The Operator shall evaluate any likely operational or organizational changes to the

facilities that will affect the emergency preparedness and response systems.

9.3 External environment

There is an expectation that the impact of the operations on the environment will be improved in the period of life extension. Plans to meet the requirements for changed regulations or



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changed operating conditions shall be evaluated. Improvements hall be evaluated. A Best

Available Technology (BAT) evaluation for discharge, emissions and energy efficiency shall be performed for the life extension period and implementation of cost efficient measures should be considered.

The validity of the discharge permission for the life extension period needs to be evaluated.

9.4 Occupational health and working environment The Operator shall evaluate the status of working environment factors that are relevant for life time extension. Factors that can be included, but not limited to are:

- chemical exposure

- lightning conditions

- ergonomics

- noise/vibrations

- material handling

- outdoor operations

- accommodation facilities in rest/restitution perspective

The purpose of the analyses is to provide a status of the working environment according to

both technical and operational requirement. The assessment shall be based upon existing analyses at the installation, if necessary follow-up with new assessment where relevant.

The risk from each finding and the overall potential (future) risks shall be evaluated before deciding on the implementation of measures for improving working environment.

9.5 Organizational and human factors The human factors area comprises methods and knowledge which can be used to assess and improve the interaction between people, technology and organization to realize efficient and

safe operations. Human factors analyses shall be performed where changes are made or where extended life challenges the established human, technology and organizational context.

The risk from each finding and the overall potential (future) risks shall be evaluated before deciding on the implementation of measures.



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Appendix 1 - Process for application for consents In order to ensure that the application is sent in due time, the Operator should start to plan the

application process early, or in line with the suggested minimum three years before the consent period expires. The applications to PSA and NPD shall be submitted one year before

the consent expires. The Operator may wish to issue a consent application for life extension earlier for business and operational planning purposes. This is to receive consent from the Authorities for the plans and to be able to proceed with activity planning and execution before

end of existing consent. This should be agreed with the Authorities.

The background technical information (Regulatory Gap identification, review of facilities technical and work environment status, technical analyses and qualifications) needs to be prepared and be relevant as basis for the consent application.

The application shall be a summary of the assessments and conclusions made by the Operator

used to decide that the existing facilities are safe and reliable to be used in the life extension period. A proposed content of the application to PSA are included in Appendix 2 and to NPD in Appendix 3.

Note that PSA can choose to control parts of the facilities, analysis or the operation as part of

audits and revisions, but this is not directly part of the consent process. It is the Operator that has the sole responsibility for the safety for the facilities and its operation.

PSA will liaise with other authorities as found relevant for the review of the application.

The proposed changes and modifications to the facilities shall be included in the application with plans and timeline for implementation. Consents may be given on the condition that the changes and modifications described in the application are implemented as planned.

Documentation of the assessments and methodologies used to arrive at the decision to extend the service life shall be stored and be available. The Operator shall describe the process for

how documentation is updated in connection with technical and organizational changes to the facilities. Updating documentation is a challenge and at many aging installations complete

updating of all documentation is not likely. The Operator shall therefore assess any increased risk due to incorrect documentation that. Personnel involved in the daily operations shall be involved in the assessment.

Proposals for changes or modifications shall be developed and the required actions may be

described in the application in such a way that there is flexibility to select better solutions found at a later stage.



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The application for consent should be based on a brief description of:

- what has been studied - what has been found - what the Operator plans to do with it, such as:

- required changes and modifications - needs for updates in maintenance (and inspection) programs

- needs for updates in the performance requirements for barriers - summary of the assessment of exemptions that needs to be continued with eventually

new compensating measures. Exemptions that need to be continued in the life

extension period can be applied for through the application for consent to PSA.

Prerequisites

According to the latest priority areas of PSA, it has to be ensured that the following is

understood and is/will be implemented:

The Operator, on behalf of a Production License, is responsible for the daily operation of the facilities and license. Hence the Operator has the overall responsibility for ensuring prudent operation and effective resource exploitation.

The Operator shall have a management system that is set up to ensure compliance with the

applicable regulations. An important prerequisite is to ensure that the Operator lives up to the requirements in:

- Management Regulations section 5 - Management Regulations section 23 and Framework Regulations section 15 (relating

to continuous improvement). In order to achieve compliance with Management Regulations section 5, the PSA has issued a

document entiteled “Prinsipper for barrierestyring i petroleumsvirksomheten” which details expectations to barrier management systems where recommendations for the establishment of

a barrier strategy and specific barrier requirements are outlined. It is expected that all critical documentation is kept updated at all times. Particular focus shall

be given to documentation critical to the prudent operation of the facilities.

It is expected that the maintenance management system is a risk based equivalent to what is defined in NORSOK Z-008 and that a maintenance management process with continuous improvement is fully implemented.



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Verification and Approval

The Operator shall ensure that the analyses and evaluation work has been carried out in accordance with the regulations, the relevant company standards and have been verified by

the appropriate technical discipline authority. The Operator shall ensure that the decision have been approved by the relevant parties in the

Operator company and the Production License partners.

The final application for consent document shall be presented to the working environment committee for comments before submitting to PSA. According to the Framework Regulations section 13, it is a requirement that the employee representatives have the opportunity to

participate to the extent that they can support the application submitted to the PSA. The involvement of the employee representatives shall be described.

Experience Transfer

The Operator shall ensure that experience on lifetime extension from other installations and operating areas is applied to the analyses and evaluations carried out for the application. Any

specific relevant information shall be included in the application document. The Operator shall seek for best practice on lifetime extension both internally and externally.

-o0o-



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Appendix 2 - Suggested contents list for an application for consent to PSA Note that the application for consent to PSA can be sent in either Norwegian or English

0. DISTRIBUTION LIST 1. INTRODUCTION

Basis for the application

Period applied for Applicable Regulations for consent Overview of the facilities and the field(s)

Plan for the future use of the facilities Overview of work on the exploitation strategy

Overview of the Principle Enterprise Description of the work performed in the application process

2. ACTIVITIES COVERED BY THE APPLICATION

Operations Maintenance Modifications

Drilling Well Operations

Decommissioning Pipelines

3. MANAGEMENT SYSTEMS HSE

Emergency response Barrier management

Organization and competence Maintenance (and inspection) Audits and verification

4. EXEMPTIONS FROM THE HSE AND RESOURCE REGULATIONS

Previously granted exemptions Evaluation and application of exemptions for life extension period



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5. ANALYSES AND EVALUATION COMPLETED AND ONGOING

Basis for the extension period Gap analysis against the Facilities Regulations

Evaluations and analysis to qualify for life extension Evaluations of safety critical systems

Evaluation of production regularity Evaluation of ’as-built’ documentation

6. EXPLOITATION STRATEGY

Plans for the facilities and field(s) Third Party evaluations

7. RISK MANAGEMENT

Quantitative risk assessment Emergency preparedness and response assessment Environmental risk assessment

Occupational health, working environment assessment

8. CONTRIBUTION FROM EMPLOYEE REPRESENTATIVES Safety Delegates

Trade Union A+B.

9. REFERENSES APPENDICES

Appendix 1 – …….

Appendix 2 – …….

-o0o-



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Appendix 3 - Suggested contents list for an application for consent to NPD The consent application should be in Norwegian unless otherwise agreed with NPD.

The following contents list is an extract from the information required in PDOs. See guideline for development of PDO for further information (Link). The following list of content can be

basis for discussion about the required content to the application to NPD: 0. DISTRIBUTION LIST

1. INTRODUCTION

Basis for the application Period applied for

Applicable regulations for consent Overview of the facilities and the field(s)

Plan for the future use of the facilities Use of third party facilities, transport systems

Overview of work on the exploitation strategy

Orders given by other authorities. Any nonconformity from originally approved plans

Description of the work performed in the application process 2. EXPLOITATION EVALUATIONS

Cost benefit analysis of uses of the facilities for life extension

Flexibility of existing facilities Reservoir history Consideration of use of new techniques for increased recovery

Consideration to ensure resource exploitation, including tail production and phase-in of third-party resources Supply security, including regularity and vulnerability

Goals and vision for HSE, including external environment and energy efficiency Basic decision criteria, with focus on HSE, economy and technology

Evaluation of the changed need for accommodation capacity Evaluation of remaining uncertainties with reasons for continuation Tie-in to other fields or facilities

Opportunities for tie-in from other fields Use of existing infrastructure beyond the design lifetime

Opportunities for unitizing petroleum activities 3. EXPLOITATION STRATEGY

Geotechnical and technical reservoir factors, as well as production schedule -o0o-

http://www.npd.no/Global/Engelsk/5-Rules-and-regulations/Guidelines/PDO-PIO-guidelines_2010.pdf



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Appendix 4 – Schematic of the application process

Identify

need for

application

Management

System

Inform and engage the partners

representatives

Inform and

engage employee

representatives

Inform and engage

the Operator

Management team

Appoint

Leader

Inform PSA and NPD of the application process and discuss way ahead

Dialog with

PSA and NPD

Establish multidiscipline team and

define roles and responsibilities

Prepare a plan

for activities

Agree the period for

the application

Identify the analyses and

evaluations required Barrier condition

Operating

condition



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Update

plan

Carry out the qualification

analysis and evaluations

Assess criticality of

identified gaps/actions

Verify analyses and evaluations

Review exemptions and deviations

Prepare an overview of major decisions,

their assumptions and basis

Prepare document to NPD

1 year review

process by PSA

Consent

given

Ext. Review

Contribution of employee representative Approve application

and send to PSA

Prepare document to PSA

Approve application and send to NPD

1 year review

process by NPD

Consent

given



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Explanation of the steps:

a. Identify need for application

The requirement to apply for consent as described in Chapter 3 and 4 shall be evaluated. It is recommended that the requirement to apply for consent for lifetime extension is put into

the Operator’s system for long term planning. The timing for starting the process should be at least three years before the consent expires.

The extent of the changes to the PDO assumptions that require an application needs to be discussed with the PSA and NPD. Note: In this case the life extension includes production

from resources outside original PDO, the requirement for a new PDO has to be discussed with the Ministry of Petroleum and Energy.

In the event of any major plans to change the use of the facilit ies, e.g late life projects, the issue of life extension shall be considered irrespective of when the period of consent is

exceeded. It is sensible to use the resources available for the lifetime project to work on an application for consent for life extension.

b. Inform and Engage the Operator Management Team

The process to prepare an application for lifetime extension is time and resource consuming. The Operator management responsible for the facilities needs to take ownership of the process from the outset. Resources need to be made available and the activities need to be

included in the company plans. Funds need to be allocated in the budget process.

The License Partners in the facilities need to be engaged in the process at the outset. The employee representatives have a major role in the application process and need to be

involved at the outset. The employee representatives are also expected to provide comments to the process and their involvement in the application document. It is advised that employee

representative(s) is appointed to follow up the process from start to finish. c. Appoint Project Leader

A project leader shall be appointed to plan the analyses and evaluations required and to

coordinate the application process. The project leader will need both internal and external resources for the work and requires therefore a clear authority and budget. The project leader will need to work with the following parties:

- discipline engineers and in particular technical authorities

- resource and area development - employee representative organizations



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- partners

d. Inform PSA and NPD

The Operator shall inform PSA and NPD of the start of the application process and arrange a meeting to discuss the following:

- the basis for the application - the period for the application

- the facilities to be covered by the application

It is important that the Operator, PSA and NPD establish a good dialog at the start of the process. It is advisable that the Operator clarify PSA’s which for further involvement in the process.

e. Prepare a plan for the activities

A plan for the activities shall be prepared showing who is responsible, milestones and deadlines, important connections and dependencies and planned meeting.

An estimate for the cost of the application process shall be included in the license budget

process. f. Define roles and responsibilities

The roles and responsibilities for the participants in the process shall be defined at the outset.

This includes personnel within the Operator’s organization and contractors required to carry out work. Ensure resources are identified and made available to cover all relevant disciplines.

g. Identify the required analyses and evaluations

The required analyses and evaluations are determined by reference to the regulations, Operator’s own assessment and experience gained from previous applications. These guidelines shall also be used to assess the required analyses and evaluations.

Analysis that is expected to be reflecting the future use on the facilities and updated in accordance with latest knowledge and experience are e.g.:

- Plans for resource exploitation incl. development of corrosive mediums - Drilling and work over plan - Barrier condition of critical systems and equipment

- Working environment studies - Life extension analysis of foundations, mooring, main bearing structures and other

critical structural components - Quantitative Risk Analysis (QRA)



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- Emergency preparedness and response analysis

- Best available technology (BAT) analysis for emissions and energy efficiency

A review of the validity and need for updates of maintenance and inspection systems as well

as area specific functional requirements for barriers shall be performed.

h. Agree the period for the application The Operator shall decide the period to be applied for.

The period can either be related to the planned period for the facilities (safety, commercial evaluation) or be based on the demonstrable technical lifetime (technical condition).

The analyses and evaluations carried out shall demonstrate that the facilities can be used in the period applied for.

The Operator may be permitted to use the facilities beyond the new period applied for by

submitting a new application one year before this period expires. i. Update the plan

An update of the plan may be done at this stage since all the assumptions for the application

process is in place. Any impact on the activities to be carried out and the time and resources required shall be assessed at this stage. Time to perform evaluations of the recommendations from the analysis, ALARP process and decision of actions shall be reflected in the plan.

j. Carry out the analyses and evaluations

Carry out the analyses and evaluations and ensure results and conclusions are available in accordance with the plan and identified needs for updated analysis in activity g .

k. Assess the criticality of gaps/actions

Gaps, actions and remedial measures that are identified in the analyses and evaluations shall be assessed for criticality in order to influence the prioritization of these in the planning

processes. The main factor for the criticality shall be the risk associated with the gap/action and it is expected that the gap/action with the highest risk has the highest priority.

l. Verify analyses and evaluations

All the analyses and evaluations carried out by internal personnel and external companies shall be verified by the Operators own personnel. It is up to the Operator to ensure the

appropriate person has the necessary competence and authority for the verification. The Operator shall prepare a plan for verification at the outset of the application process.



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m. Review exemptions and deviations Any exemptions that have been given by the authorities for the facilities shall be evaluated

whether it is acceptable to continue with the exemptions through the period applied for.

In the event that a new non-conformity from the valid Facilities Regulations is discovered during the life extension process, it shall be applied for.

n. Prepare overview of major decisions

The Operator shall prepare an overview of the major decisions that can affect the future for the facilities and can influence the review of the application. The basis for the major decisions shall also be referenced. It is advisable that this is discussed with PSA and NPD through the

application process.

o. Prepare document Typical contents list for an applications for lifetime extensions are included in Appendix 2

and 3 of these guidelines.

p. Contribution of the employee representatives The employee representatives shall be involved in the application process and have the

opportunity to comment on the application and the application process. The comments shall be included in a separate section in the consent document.

q. Approve application for consent document and send to PSA and NPD

The application for consent shall be approved by the Operator’s management before it is sent to PSA and NPD.

The Operator’s management shall confirm any commitment included in the application and verify the assumptions that form the basis for the application.

r. Review process

The review of the application can be a significant effort and needs to be planned. The Operator shall make personnel available to assist in the review process and to have dialog on the main issues with the PSA and NPD. The employee representative organizations shall

also ensure personnel are available for follow up of the review process.

s. Consent given



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The overall objective is to have the application for consent approved by PSA and NPD before

the consent period is exceeded.

-o0o-

0- OLF Recommended Guidelines for the Assessment and Documentation of Service Life Extension of Facilities, Rev 1, 040612

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