Analysis of Plant Ageing and Safety Regulations

The assignment includes a list of references to various reports and studies on plant ageing, including the HSE Report RR509, the IAEA Safety Guide NS-G-2.12, and the UNI/TS 11325-8. It also provides information on the management of equipment containing hazardous fluids or pressure, as well as lessons learned from major accidents related to plant ageing. The assignment is likely intended for students in a course related to chemical engineering or process safety.

Running head: Health and Safety 1
HEALTH AND SAFETY
Student Name
Institution

Health and Safety 2
Table of Contents
1. Introduction.........................................................................................................................................2
2. Analysis...............................................................................................................................................2
2.1 Business case for extending the life of ageing installations in the North Sea.....................................2
2.2 Risk management and Asset integrity of North Sea installations.......................................................4
2.3 Developments in knowledge and/or technology advancement...........................................................6
2.4 Changes in the organization and skills/knowledge............................................................................7
2.5 Statistics relating to ALE for example from the HSE, Oil and Gas UK............................................9
2.6 Legislation relating to ALE in the North Sea – Health and Safety Executive/Energy Division (HSE
ED)........................................................................................................................................................10
3. Rebuttal.............................................................................................................................................12
4. Conclusion.........................................................................................................................................13
5. References.........................................................................................................................................13

Health and Safety 3
1. Introduction
Many oil and gas installations in UK’s North Sea oil reserves have remained in operation
beyond operation life. Operation of ageing installation presents numerous challenges to health
and safety of both staffs and environment. The need to extend the life of ageing assets is subject
to provisions of guidelines developed by Health and Safety Executive (HSE). The phenomenon
has lead to enactment legislation and standards that assist in installation and maintenance of
various assets in the North Sea. Some of the reasons for extended life of assets include
decommissioning cost, the time it takes to decommission assets and the cost to dismantle the
ageing assets. Statistics show the cost of maintaining ageing assets and cost attributed to both
accidents and repairs of these assets. The following report provides analysis of Ageing and Life
Extension issues in the oil and gas reserves of UK’s North Sea (Rademaeker et al 2014, pp 280-
291).
2. Analysis
2.1 Business case for extending the life of ageing installations in the North Sea
There are very many reasons for extending the life ageing installations in companies
involved oil production in the North Sea. Firstly, collapse in the regional oil price has caused
many companies to re-evaluate the economic viability of changing ageing installations. The
problem of oil prices is also making oil unprofitable in the contemporary market especially for
those small companies operating within these regions. In addition, Years of higher-than-break-
even oil prices are causing companies to implement ageing installations strategies. These

Health and Safety 4
changes in oil prices have also caused job losses leading to approximately 124000
unemployment in the sector (HSE 2002, pp 028).
Secondly, the scale of the job to replace the ageing installations is challenging since the
number of installations is more than1357 offshore installations in OSPAR maritime area. It is
estimated that 545 of these installations are fixed steel. More than 80% of these offshore
installations according to HSE IS9 (2004), should be out of service due to ageing by 2030. The
overall cost of replacing or decommissioning of ageing installations is estimated to exceed £47
billion. The operation life is expected to go beyond this field life since the complexity of
handling these installations present the primary challenge (Milazzo & Aven 2012, pp 183-192).
Thirdly, decommissioning of ageing installations in the North Sea presents over time and
over budget. Though ageing installation present health and safety challenge the decommissioning
of these installations takes overtime of up to 30 years. For instance, decommissioning of some
installations in the North Sea that were supposed to cost 10-15% of the construction budget
exceeded the cost by 40% of the budget. The length the time that decommissioning of ageing
installation takes has proved that the task involves is much more than the estimated time frame
(HSE 2008, no.044).
Thirdly, replacing ageing installations is quite challenging for smaller companies
operating within the region. Replacing ageing installations cause collapse of more than 100
companies in the United States of America. The cost of replacing and decommissioning ageing
installations that are also coupled with the high expert requirement is quite tricky for young
struggling companies. For instance, Tuscan Energy in 2005 was saved from the cost to required
decommission companies within UKCS and NCS due to its insolvency. Moreover, the cost of

Health and Safety 5
new installation must also factor the labor and expertise required for dismantling those ageing
installation in the sea (HSE 2006, no.509).
Finally, some young companies operating in the North Sea has limited resources and this
present challenges in facing out the ageing installation. The central argument is the unchartered
work presented by decommissioning of ageing installation making operation life of this
installation to go for many years. In addition, these young companies that are on the verge of
being wiped out by large companies have a limited budget for decommissioning ageing
installations (Zuccarelli et al 1991, pp 43-48).
2.2 Risk management and Asset integrity of North Sea installations
One of the trickiest aspects of the North Sea installations involves risk management and
assets integrity. As a health and safety practitioner ageing installations are risky to both life and
environment due to continued deterioration and loss of integrity. Studies indicate that blast walls
connection are currently worn out and without replacement, the integrity of asset is
compromised. Assets integrity of the North Sea installations requires high-risk management
assess and ensure there are risk mitigation guidelines as provided by Health Safety Executive
(HSE) (HSE 2002, pp 028).
Focusing on the assets integrity management is important for is key to monitoring and
evaluation of risk or asset integrity. Some of the health and safety concerns include time-
dependent mechanisms, damage or deterioration with time and external changes with time.
Firstly, the time-dependent mechanism includes the fact that most assets have a specific lifespan
beyond which metallic parts are corroded, and creep for non-metallic parts. Ageing installations
become health and safety concern when the assets are past the expected lifespan. Secondly,

Health and Safety 6
damage and deterioration is another health and safety concern due to environmental overload and
accidental damage. With time various assets become subject to risk due to damage posing risk to
operators and the public in general. Thirdly, external changes that occur over time include
failures to upgrade assets according to current technologies and risk management strategies
(Horrocks et al 2010).
There are some risk management strategies that are grounded in both legal provisions and
technical capabilities. Some of the mechanisms to tackle the ageing risk include regulatory
provisions, safety management system, risk assessment and stakeholders’ engagement. Firstly,
there are many different UK regulatory provisions that take care of the ageing and life extension
installations. Some of these include DCR (1996), PFEER (1995), PUWER (1998), SCR (2005)
and MHSWA (2003). These regulatory provisions offer the entire requirement for an extension
beyond the life of various assets in UK oil and gas production especially on North Sea (Sharp,
Stacey & Birkenshaw 2001). Secondly, safety management system provides various activities
that involved in management and assessment of ageing or asset integrity. For instance, safety
management system gives various technical policy and strategies to review safety standards of
ageing assets. Thirdly, another risk management mechanism involves risk assessment guidelines
as provided by Health Safety Executive (HSE) for assets managers. Finally, various stakeholders
are involved in risk management through provision of training, seminaries and safety meeting to
deliberate on safety procedures involved in the maintenance of ageing assets (UNI/TS 11325-8
2013).

Health and Safety 7
2.3 Developments in knowledge and/or technology advancement
Development in knowledge and advancement in technology is one of the reasons for the
loss in the usefulness of many assets. Changes in knowledge, technology, and standards of assets
management indicate that most of the assets are currently operating beyond the original field life.
This is very challenging for the health and safety gave the dangers that this ageing installation
poses to life and the environment. Development in knowledge and technology advancement
provides the basis for both extending filed life and development of new technologies in oil and
gas field (Chockie & Gregor 2006, no.23).
Changes in engineering standard are one of the challenges that result from development
in knowledge and advancement in technology. Engineering standards provide a requirement for
replacing assets parts and various components of ageing infrastructure in the North Sea. Firstly,
increase in age and deteriorating assets condition makes it difficult to replace ageing installations
(Sharp, Stacey & Birkenshaw 2002, no 28610). The ageing installations compromise the steel
integrity making it difficult to extend the life of the installation in the oil and gas production as
this also contradicts the engineering standards. Secondly, increasing dependant on the existing
technologies for the development of other installations making it challenges to replace these
systems. This implies that development of the technologies used in oil and gas production also
depends on the ageing installations for development of new ones. This also compromises the
integrity of these installations that have been used past field life. Thirdly, development in
knowledge should improve the quality of inspection and analysis of those ageing materials that
necessitate life extension. In addition, development of knowledge should provide early indicators
for ageing and obsolescence of these assets (ARIA Database Eds 2006, pp 112-127).

Health and Safety 8
2.4 Changes in the organization and skills/knowledge
There are various changes in the organization that influence the extension of the life of
ageing installation in the North Sea. Changes in the organization are mostly influenced by
financial or economic reasons. Some of the most common change within the organization is
reducing the number of staff, reorganizing departments and teams or adopting ‘flexible working’
(Zuccarelli et al 1991, pp 43-48).
Reducing the number of staffs is one of the common changes that highly play a
significant role in the integrity of assets. Firstly, reducing the number of staffs compromises the
knowledge as experts are laid off leading to low maintenance and risk management. Reducing
the number of staffs means high workload for the remaining staffs and this is risky for risk
assessment and inspections. Health and safety executive have also raised concerns due to limited
safety conditions that result from a low number of employees and experts in some companies
within the North Sea. Secondly, reducing the number of staffs also influences the knowledge
changes since some specialized staffs are leaving the company. Maintenance of assets also
depends on the knowledge from staffs and a low number of staffs present challenges to
maintenance (Horrocks et al 2010).
Reorganizing departments is another change that normally occurs within an organization
that has affected the assets with oil and gas production. Changes in organization management
have potential risk and maintenance of assets. For instance, US refinery in February 1999 killed
four workers and injured many yet the audits revealed that the explosion resulted from poor
maintenance due to organization changes (International Atomic Energy Agency 2009).
Reorganization of the department within an organization is the chief source of communication
breakdown that limits knowledge and skills to maintain assets. The guidelines for effecting

Health and Safety 9
changes in organization and reorganizations of department require proper safety measures and
prior communication for integrity maintenance. Moreover, reorganizing teams also is a precursor
to skills loss since skilled staffs are transferred to other areas not originally intended (Fanning
2003).
Adopting flexible operational and maintenance working is another organizational and
knowledge change that is also affecting most companies that may result in poor ageing and life
extension of assets. Sometimes the management effect changes in the bead to adopt a more
flexible operational and management structure that is more compromised than the existing one.
This is coupled with poor safety measures when maintaining assets. In contrast, safety
operational changes can also help improve challenges that have been experienced by these
companies when running maintenance operations. Adopting a more flexible operational and
maintenance working can help improve risk assessment and management procedures (Bragatto,
Della & Faragnoli 2012, pp 177-182).
Companies have developed the risk management strategies that are adapted to help
prevent loss of skills, knowledge, and safety in case of organization changes. Firstly, proper
communication of changes to staffs before effecting these changes in the organization. Secondly,
consulting properly enough with staffs involved in changes to ensure that there is no breakdown
in operational working that compromises safety. Thirdly, understanding and evaluating the risks
associated with changes before implementing those proposed changes. Understanding risk helps
the company to consider all the risk mitigation options and act responsibly (API 580 2009, pp
280).

Health and Safety 10
2.5 Statistics relating to ALE (Ageing and Life Extension) for example from
the HSE, Oil and Gas UK
Ageing statistics indicate that there are many installations that are beyond their original
operation life. For instance, the ageing study carried out by HSE indicates that more than 50% of
the current installations found in the North Sea have exceeded the original 25 years operation
life. This poses a high risk since it is estimated that the ageing and risk associated with ageing
begins immediately the assets enter the sea. Moreover, the more these installations continue to
offers services to the companies, the ageing installation becomes and the number of older
systems increases with time (Chockie & Gregor 2006, no.23).
Safety statistics by HSE indicates there are many accidents and illness associated with
working in ageing installations. Firstly, more than 36 injuries were reported during 2011/12 as
compared the previous years of 41 injuries. This number is derived from 29,058 offshore
workers in 2011/12 when compared to 27,600 workers in the previous year. In addition, the fatal
rate includes 130.77 per 100,000 workers as compared to 51.84 in the previous year. Injuries are
due to accidents such as fall that represent 17 in number, hit by moving object represent 7 of the
number and handling of load account for 7 which is 86% of the total injuries. Limbs injuries
account for 64% of the total injuries translating to 24 injuries (Wintle, Moore, Smalley &
Amphlett 2006).
Economic statistics show a high cost of maintenance and repair of these ageing
installations. Economic statistics can be grouped into the cost of corrosion, loss of life and
injuries, cost of maintenance. Firstly, corrosion and repairs for assets in the North Sea have cost
companies within UK huge sum of money. For instance, in 2002 NACE cost of corrosion study

Health and Safety 11
indicate that more than 3.1% of GDP translated to $1.4 Billion annually goes to corrosion-related
repairs. Secondly, loss of life and subsequent injuries that are estimated at 11 deaths and more
than 180 injuries accounted for the loss of €170Million. More than 425 occurrences are
reportedly dangerous to life result from the release of hydrocarbons due to corrosion. Of these
occurrences, 30% are due to equipment failures, hydrocarbon releases account for 29.9%, well-
related incidents account for 10.1 % and fire offshore 6.8 % (Gyenes & Heraty 2016, pp 733-
738).
2.6 Legislation relating to ALE (Ageing and Life Extension) in the North Sea –
Health and Safety Executive/Energy Division (HSE ED)
Legislations have been developed by Health and Safety Executive/Energy Division (HSE
ED) to help monitor, regulate and protect key players with ageing installations. These
legislations also protect the integrity of ageing installation against any risk such as leak or
explosion. These regulations can be grouped into safety regulations, maintenance regulations,
life cycle regulations, and organizational regulations.
Safety regulations include all standards set to address health and safety concerns before
installation of these assets in the North Sea. There are various regulations that provide standards
such as SCR (2005) which offers various safety standards to be fulfilled before any installation.
The legislation further gives safety standards during installation to avoid any future risk
associated. In addition, SCR (2005) also provides and foresee the ageing life extension for these
installations before they are put in place. Another safety regulation includes PFEER (1995) that
provides safety measures required in designing, detecting, protective and control measures for
these ageing installations and possible life extension (Bragatto et al, 2015, pp 271-276).

Health and Safety 12
Maintenance regulations include those health and safety procedures set for operational
maintenance of ageing installation including life extension. An example of these regulations or
legislations includes DCR (1996) that provides the health and safety measures concerned with
periodic maintenance, performance standards and Independent verification by ICP (Flage &
Aven 2009, pp 9-18). Firstly, UK regulation under legislation DCR (1996) gives direction on the
maintenance that is required for those companies that are operating offshore oil and gas
installations in the North Sea. Secondly, this legislation also provides the basis of performance
standards used to assess the ageing installation under risk management guidelines. Thirdly, DCR
(1996) provides grounds for independent verification by ICP as an aspect of maintenance
management process that also ensures that companies only work according to requirement.
PUWER (1998) is another regulation that also provides various standards that are used in the
maintenance of hazardous equipment and the necessary inspections (Cutts 2005).
Life cycle regulations include those technical policies and guidelines that are required to
assess and review the life cycle of all assets. PSR (1996) is a good example of those legislations
that provides the requirement for life extension beyond the set life cycle. This legislation is
concerned with the maintenance of pipelines in a state that can continue to work beyond the
ageing field life. The legislation also set standards involved in inspection and evaluation of the
risk that may result in the short life cycle for those installations expected to last for longer period
of time beyond field life (Herbert 2001, pp34–80).
Some other regulations and legislation provide policies and guidelines for organization,
planning and performance reviews. For instance, HSWA (1974) / MHSWA (2003) that gives the
basis of incorporating modern codes and organization policies to ensure good maintenance of
these systems. Modern codes and standards offer the foundations that are used to upgrade or

Health and Safety 13
maintain various components of offshore installations. Organizational changes have a direct
influence on maintenance and operations aimed at repairs of offshore installations. The
legislation provides a requirement that helps facilitate organizational planning and policies that
are also used in inspection of these installations. Furthermore, this legislation contains guidelines
and procedures required in review and audit of various aspects of offshore installations (Ersdal &
Langen 2002, pp 4276-433).
3. Rebuttal
Despite all the necessary precautions and measures put in place to guide the installation
and maintenance of ageing installations in the North Sea, health and safety of operation are
challenging. As health and safety practitioner, most of the ageing installation consider economic
and financial of the company and staffs and this compromises environmental and human health
(Chockie & Gregor 2006). Explosions that may result from ageing and corroded assets are fatal
to human life and very disastrous to the environment. Secondly, life extension of ageing assets
offers high maintenance cost to ensure minimal risk associated with these installations. Ageing
installations pose a high risk as compared to the risk mitigation procedures put in place. Thirdly,
assets integrity reduces the ageing of installation making maintenance difficult and risky for
personnel involved. Though the primary concern of HSE is the integrity of assets, ageing
installations and life extension make assets have low integrity. Without serious consideration of
the danger posed by ageing assets, injuries and death are most likely to increase given that more
than 50% of assets in the North Sea are past operation life (Catterson et al 2013, pp 271-276).

Health and Safety 14
4. Conclusion
In conclusion, Ageing and Life Extension (ALE) of oil and gas assets in the North Sea is
a phenomenon that has helped much old oil and gas installation continuo beyond operation life.
Business factors and technological factors are the main reason for extending the life of many
assets in the North Sea. Organization change and policies are the core of life extension of ageing
installation without compromising assets integrity. There is a legal backup that facilitates
installation, maintenance and decommissioning of oil assets. In addition, statistics give the
economic implication of accidents and maintenance of these ageing installations. Development
of knowledge and skills or technology is another factor that facilitates ageing and extension of
the life of North Sea oil installation. Despite all safety measures instituted by HSE, ageing
installations pose high human and environmental risk.

Health and Safety 15
5. References
API 580, 2009, Risk Based Inspection, Washington, D.C., US. Pp 280
ARIA Database Eds.: Lars P, & Kaisa S, 2006, ESReDA Working Group Report, Ageing of
Components and Systems. Det Norske Veritas, pp 112-127.
Bragatto, P, et al, 2015, Reviving knowledge of equipment failures and improving risk
management at industrial sites, Journal of Applied. Eng. Sci. 13 (4), 271-276.
Bragatto, P; Della SC, & Faragnoli, A, 2012, Opportunities and threats of risk-based inspections:
The new Italian legislation on pressure equipment inspection, Chemical Engineering
Transactions 26, pp 177-182.
Catterson, V.M., et al, 2013, Increasing the Adoption of Prognostic Systems for Health
Management in the Power Industry, Chemical Engineering Transactions 33, pp 271-276.
Chockie, A, & Gregor, F, 2006, Ageing management and life extension in the US nuclear power
industry. Report prepared for PSA project reference NO 99B16, CGI report 06.23.
Cutts, S, 2005, Offshore Safety Division’s response to concerns about installation integrity on
UKCS. Paper SPE 96318 presented at Offshore Europe, Aberdeen.
Ersdal, G, & Langen, I, 2002, On the assessment of existing offshore structures. Proc 12th
ISOPE conference, Japan, pp 4276-433.
Fanning, FE, 2003, Basic Safety Administration: A Handbook for the New Safety Specialist,
Chicago: American Society of Safety Engineers

Health and Safety 16
Flage, R., & Aven, T., 2009, Expressing and communicating uncertainty in relation to
quantitative risk analysis (QRA). Reliab. Risk Anal. Theor. Appl. Vol.2, no.13, pp 9-18.
Gyenes, Z., & Heraty WM, 2016, Lessons learned from major accidents relating to the ageing of
chemical plants, Chemical Engineering Transactions, 48, pp 733-738 DOI:10.3303/CET1648123
Herbert, AK, 2001, A Short History of Occupational Health (PDF). Journal of Public Health
Policy, vol.22, no.1, pp34–80
Horrocks P, et al, 2010, Plant Ageing Study Phase 1 Report., Health and Safety Executive Report
no. RR823
HSE, 2002, Transient Vibration Guidelines for Fast Acting Valves – Screening Assessment. HSE
Offshore technology Report OTO 2002, pp 028.
HSE IS9/2004, 2004, Guidance on the management of ageing and thorough reviews of ageing
installations. Health and Safety Executive
HSE, 2006, Plant ageing – management of equipment containing hazardous fluids or pressure.
Health and Safety Executive Research Report 2006/509.
HSE, 2008, Review of corrosion management for offshore oil and gas processing. Revision of
HSE OTO Report 2001/044, 2001. To be issued.
International Atomic Energy Agency, 2009, Safety Standards for protecting people and the
environment. Ageing Management for Nuclear Power Plants, Safety Guide No. NS-G-2.12
Milazzo, MF, & Aven, T, 2012, An extended risk assessment approach for chemical plants
applied to a study related to pipe ruptures, Reliab. Eng. Syst. Safe. Vol.99, pp 183-192.

Health and Safety 17
Management of equipment containing hazardous fluids or pressure, Health and Safety Executive
Report no. RR509
Rademaeker, E, et al, 2014, A review of the past, present and future of the European loss
prevention and safety promotion in the process industries, Process Safe. Environ. Vol.92, no.4,
pp 280-291.
Sharp, J V, Stacey, A & Birkenshaw, M, 2001, Lifecycle integrity of North Sea installations.
Proc 11th ISOPE conference, Stavanger.
Sharp, J V, Stacey, A & Birkenshaw M, 2002, Reassessment issues in life cycle structural
integrity management of fixed steel structures. Proc 21st OMAE conference, Oslo, Mattoc, paper
no 28610.
UNI/TS 11325-8, 2013, Planning of maintenance of pressure equipment through methodologies
based on risk assessment (RBI), Milano, IT (in Italian).
Wintle, J; Moore, P; Smalley, S, & Amphlett, G, 2006, HSE RR509/2006, Plant ageing
management of equipment containing hazardous fluids or pressure. Research Report 509.
Prepared by TWI Ltd, ABB Engineering Services SCS (INTL) Ltd and Allianz Cornhill
Engineer for the Health and Safety Executive. Norwich, United Kingdom.
<http://www.hse.gov.uk/research/rrhtm/rr509.htm>
Zuccarelli F, et al., 1991, Lifetime extension of existing offshore structures. Proc 1st ISOPE
conference, Edinburgh, pp 43-48.