ABS N-Notation for Mobile Offshore Units

Operating on Norwegian Continental Shelf

CLIENT VISIT

Agenda

Verification methodology
 Acknowledgement of Compliance (AoC)

PSA regulations

ABS status with Norwegian Maritime Directorate (NMD)

ABS classed units with N-Notation

Scope of ABS notations

Regulatory considerations

ABS Guide for the Norwegian Continental Shelf

Additional PSA requirements outside the scope of N-Notation

Commonly known additional requirements for the NCS

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Verification Methodology:
Acknowledgement of Compliance (AoC)

An AoC is a decision made by the Petroleum Safety Authority
(PSA) demonstrating that the following aspects provide sufficient
confidence that petroleum activities can be conducted safely
within the requirements of the framework regulations
 Technical condition of an Mobile Offshore Unit (MOU)
 Applicant’s organization
 Applicant’s management systems

AoC is mandatory on Norwegian Continental Shelf (NCS)

Verification Methodology:
Acknowledgement of Compliance (AoC)

AoC mandatory on Norwegian Continental Shelf (NCS) for the
following units
 Mobile facilities registered in a national register of shipping and is to
work in the petroleum activities.
 An AoC is also mandatory for
– Drilling facilities
– Living quarters facilities
– Facilities for production, storage and offloading
– Facilities for drilling, production, storage and offloading
– Well intervention vessels

An AoC is the Contractor’s responsibility.

The Handbook for application for AoC can be downloaded from
 http://www.olf.no/no/Publikasjoner/Retningslinjer/BoringDrilling/065/?
guidelineLanguage=1
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Verification Methodology:
Acknowledgement of Compliance (AoC)
Consent to Operate

An AoC alone, allows for the unit to enter the NCS but does not allow for
petroleum operations to be undertaken

A further Consent to Operate is required

It is often best to have an AoC application accepted prior to requesting
for a Consent to Operate. However, it is also possible to apply for both
simultaneously.

Additionally, units must be:
 Classed by an MOU class society – such as ABS
 Registered by a flag Administration

Consent to Operate is the operator’s responsibility

The PSA Regulations

MOUs are to comply with the latest edition of the PSA regulations,
the standards referred to therein and associated guidelines
 The framework regulations
 The management regulations
 The technical and operational regulations
 The facilities regulations
 The activities regulations

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ABS Status with Norwegian Maritime Directorate

Effective 1 February 2009, ABS was appointed as a Recognized

Organization (RO) for mobile offshore units (MOUs) by the
Norwegian Maritime Directorate (NMD) and thereby authorized to
perform on it’s behalf – technical verification, inspection and
surveys for the delegated items concerning MOUs which are or
will be registered in a Norwegian Ship Register

ABS Classed Units with N-Notation

The following units have been assigned the N-Notation

 MAERSK REACHER – SEDU
 ROWAN GORILLA VI – SEDU
 ROWAN GORILLA VII – SEDU
 SCARABEO 5 – CSDU

 HAVEN – classed with ABS

and operating in Norway
although the N-Notation
has not been requested
at this time.

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Scope of the ABS N-Notations

ABS services performed in accordance with the N-Notation

provide a means of documenting technical requirements related
to the classification for compliance with verification obligations
associated with operation of MOUs on the NCS

These can then be used as a contribution to the owner’s
application for an Acknowledgement of Compliance

To assist with the application for an AoC, a
MOU is to meet the requirements for the
N-Notation as described in the appropriate
sections of Chapter 3 of the N-Guide. The
N-Notation is obtained by the unit holding
class certificates, being flagged and meeting
supplementary requirements of PSA and
NMD

Types of the ABS N-Notations

Type of MODU Notation

 MODU (Self-elevating) A1 Self-elevating Drilling Unit (N)
 MODU (Column Stabilized) A1 Column Stabilized Drilling Unit (N)
 MODU (Ship) A1 Drilling Unit (N)
 MODU (Barge) A1 Barge Drilling Unit (N)

Type of System Notation
 Drilling System CDS (N)

Other types of units designed as MOUs which do not fall into the
above categories, such as accommodation units and offshore
support vessels, may be treated on an individual basis and
assigned an appropriate classification notation similar to the
notations above.

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Types of the ABS N-Notations

Type of MOPU Notations

 FPS A1 Floating Production (and Offloading) System (N)
 FPSO*** A1 Floating Production, Storage and Offloading System (N)
 FOI* A1 Floating Offshore Installations (N)
 FSO** A1 Floating Storage and Offloading System (N)

* FOI Notation means that although the offshore unit is fitted with
production facilities, the owner did not desire classification of the
production facilities

** The AoC scheme is mandatory for all types of mobile units except
floating storage offloading units, which may be subject to a “Request for
Consent to Operate”

*** “Self-operated” FPSOs (i.e., operated by the oil company) are also not
subject to AoC, but are operated under a consent instead. For FPSOs
operated by a separate entity from the oil company, the AoC is required.

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Regulatory Considerations – Maritime Approach

MOUs may be accepted for operation on the NCS by applying

Chapter 1, Section 3 of the framework regulations for marine
aspects as an alternative to direct compliance with the PSA
facility regulations. The unit must be registered and comply with
classification procedures with five yearly renewal surveys.
 Section 3 of the Framework Regulations enables the following to be
used as basis for documentation of AoC compliance
– Rules and regulations issued by Norwegian Maritime Directorate (NMD)
– Supplementary classification rules and certificates
– Maritime certificates issued by flag State Administration and associated
Rules and regulations to which certificates are issued
– Verification reports or Statement of Compliance (SoC) issued by
consultants and/or technical specialists for the owner and/or operator

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Acknowledgement of Compliance –
Maritime Approach

Maritime approach covers aspects such as:
 Hull
 Legs
 Stability
 Living quarters
 Mooring
 Ballast systems
 Machinery
 Fire protection

These may be reviewed in accordance with ABS class Rules, flag
and NMD Regulations

For lifeboats, the NMD Regulation for Lifesaving Appliances can
no longer be applied. Free-fall lifeboats are required.
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Acknowledgement of Compliance –
Items Additional to the Maritime Approach

For units with drilling or production plants, the PSA Regulations
must be applied.

Drilling units with ABS CDS(N) Notation will be review to ABS
Rules and additional NORSOK standards as required by the PSA

For production units with ABS FPS(N) or FPSO(N), the systems
will be reviewed to ABS Rules and additional NORSOK and ISO
standards as required by the PSA

The working environment must comply with PSA regulations and
is outside the scope of the N-Notation. ABS affiliated company,
ABS Consulting, can provide the necessary services for review of
the working environment.

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Classification Principles & Procedures

The N-Notation will be issued based on satisfactory completion of

the following activities
 Design verification
 Certification of supplier-provided materials and equipment
 Surveys during construction
 Surveys after construction

It is recommended that the PSA be contacted at an early stage of

the project to facilitate the identification of, and properly address,
major issues that may arise with respect to the acceptance of the
unit.

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ABS Guide for Mobile Offshore Units Operating on

Norwegian Continental Shelf, N-Notation

How does compliance with the N-Guide contribute to the AoC
process and how does it address the necessary aspects of the
Framework Regulations Sec. 3?
 Addresses all necessary classification Rules
 Covers flag State requirements
 Incorporates the NMD regulations into the class review process
 Addresses additional PSA regulations specific to drilling equipment
 Addresses additional PSA regulations specific to production
equipment and systems
 Addresses additional PSA regulations specific to well intervention
equipment and systems

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ABS Guide for Mobile Offshore Units Operating on
Norwegian Continental Shelf, N-Notation

Addressed all necessary Classification Rules
 As part of the maritime approach ABS will apply the latest ABS Rules
at the time of design and construction
 Additionally the ABS N-Guide contains Appendix 1, which addresses
any gaps identified between ABS Class Rules and Standards
referenced by the PSA required in the “Alternatives to Facilities
Regulations”

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ABS Guide for Mobile Offshore Units Operating on

Norwegian Continental Shelf, N-Notation

Flag State Administration
 As part of the classification process, ABS will issue maritime
certificates on behalf of flag State Administration. Which again form
part of the supporting documentation required under Framework
Regulations Sec. 3.

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ABS Guide for Mobile Offshore Units Operating on
Norwegian Continental Shelf, N-Notation

Incorporates NMD regulations into the class review process
 This follows a similar format to the AoC Handbook Enclosure D

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ABS Guide for Mobile Offshore Units Operating on

Norwegian Continental Shelf, N-Notation

Addresses additional PSA Regulations specific to Drilling equipment

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ABS Guide for Mobile Offshore Units Operating on
Norwegian Continental Shelf, N-Notation

Addresses additional PSA regulations specific to production equipment
and systems

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ABS Guide for Mobile Offshore Units Operating on

Norwegian Continental Shelf, N-Notation

Addresses additional PSA regulations specific to well intervention
equipment and systems
 Drilling derrick – NORSOK D-001 and N-001
 Work floor equipment and systems – NORSOK D-001 and D-002
 Bulk and drill fluid systems – NORSOK D-001 and D-002
 Well control equipment and systems – NORSOK D-001, D-002 and
D-010

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 Overlap Between ABS Class / NMD / PSA
ABS N-Notations (including
PSA : -Risk analysis
NMD Regulations)
-Winterization
-Working Environment
-Pollution Protection

ABS Class ABS Consulting

+ Flag can help

Owner and Operator:

-Management Systems
-Regularity and Reliability
-Operational Procedures
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Maintaining the N-Notation

An AoC requires the unit to comply with the latest regulations at the time of
issuance or renewal. Therefore the unit should continue to comply with
these Regulations for the entire duration on the Norwegian Continental
Shelf.

In order for the N-Notation to better suit the needs of the owner, it is
required that gap analyses are to be carried out by the applicant at intervals
not exceeding five years and before completion of the Special Periodic
Survey. Should this not be followed, the N-Notation may be dropped.

Any identified deviations, as a result of the above verification process will be
listed for further actions and where modifications are considered necessary,
these will be dealt with in the first instance between the owner (applicant)
and ABS.

It is to be noted, that the owner (applicant) must document all deviations
including those that have been satisfactorily resolved in his application to
the PSA for an Acknowledgement of Compliance (AoC).

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Additional PSA Requirements Outside the Scope
of N-Notation

The following items subject to PSA requirements for the AoC
application are outside of the scope for N-Notation.
 Drilling plant – can be included as part of CDS-Notation
 Cranes and lifting appliances – this can be done as part of the ABS
CRC-Notation if requested

ABS Consulting can assist with these services:
 Aviation Assessments
 Emergency preparedness
 Owner’s management systems on board and onshore
 Development of risk analysis
 Working protection and working
environmental issues
 European Union (EU) Directives

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Additional PSA Requirements Outside the Scope

of N-Notation
 Regularity and reliability issues
 Protection against pollution
 Operational requirements
 Winterization and Arctic operational
issues
These items are also outside the scope of
the N-Notation:

Prevention of harmful effects of tobacco
 Welding central
 Water quality

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Additional Technical Requirements for NCS

Drilling equipment must be in compliance with

NORSOK

Production facilities must be in compliance with
NORSOK

Free-Fall lifeboats must be used

NMD Helideck regulation requires the helideck to
be 1.25 x D (where “D” is the greatest length or
width of a helicopter, including rotors when both
rotors are turning)

Deck cranes must be certified to EN-13852-1

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References

ABS Guide for Mobile Offshore Units Operating on the Norwegian

Continental Shelf, N-Notation
 http://www.eagle.org/eagleExternalPortalWEB/appmanager/absEagl
e/absEagleDesktop?_nfpb=true&_pageLabel=abs_eagle_portal_rule
s_guides_download_page

Latest copies of the regulations and their respective Guidelines
are publically available at
 http://www.ptil.no/pdf-version-printouts/category474.html

Acknowledgement of Compliance Handbook
 http://www.olf.no/no/Publikasjoner/
Retningslinjer/BoringDrilling/065/

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www.eagle.org