Significant changes to a facility require validation

Article published in the Regulator | Issue 2: 2017 

Recently, a facility operator submitted a safety case revision for a well abandonment campaign that introduced the installation of numerous pieces of temporary safety-critical equipment at the facility in order to undertake the well abandonment work. With the introduction of additional temporary safety-critical equipment, the proposal was considered to be a modification and significant change to the facility.

NOPSEMA reminds operators that, in accordance with sub-regulation 2.30(3) of the Offshore Petroleum and Greenhouse Gas Storage (Safety) Regulations 2009 (Safety Regulations), if you seek to propose to modify or decommission your facility then you must develop a scope of validation and gain NOPSEMA’s agreement on that scope before you submit your revised safety case. The acceptance of a revised safety case for a modification is then contingent on the provision of a satisfactory validation.

Validation is a statement in writing by an independent validator regarding the matters (design, construction, and installation) covered in an agreed scope of validation. In accordance with regulation 2.40 of the Safety Regulations, NOPSEMA may require an operator to provide validation in respect of a proposed significant change to a facility. It is NOPSEMA’s policy to always require validation in the case of the installation of temporary safety-critical equipment associated with well abandonment campaigns.

To assist facility operators in meeting these requirements, NOPSEMA has developed a Validation guideline (GL0525). In addition, NOPSEMA has a Scope of validation matrix form (FM0325), which been enhanced to include the requirements for well abandonment spreads. These documents, and others, can be found on NOPSEMA’s website at www.nopsema.gov.au/safety/safety-case/validation.