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OFFICIAL
UK – ENVIRONMENTAL EMERGENCY RESPONSE ARRANGEMENTS
EUOAG WORKSHOP30 June 2016
Nicholas Woollacott
Offshore Environmental Inspector
Department of Energy & Climate Change
Agenda
• Summary of the UK regime to respond to environmental
incidents from offshore oil and gas operations;
• Implementation of the OSD requirement to demonstrate
oil spill response effectiveness as part of the IERP;
• Implementation of the OSD requirement to specify an
inventory of available oil spill response equipment as part
of the IERP; and
• Environmental IERP requirements for Non-Production
Installations and links to the UK safety case regime.
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Environmental Emergency Response
• DECC – UK Regulator for the environmental aspects of
Offshore Oil and Gas Industry. Part of the new Competent
Authority – Offshore Safety Directive Regulator (OSDR)
• The International Convention on Oil Pollution
Preparedness, Response and Co-operation 1990
implemented by domestic regulation for offshore oil and
gas installations and pipelines
• Operators (and NPI owners) required to hold an approved
Oil Pollution Emergency Plan (OPEP) for any operation
that presents a risk of oil pollution
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Environmental Emergency Response
• All OPEPs must be compatible with the UK National
Contingency Plan which provides the Strategic Overview
for Responses to Marine Pollution from Shipping and
Offshore Installations.
• The ‘Responsible Person’ for OPEP submissions and
subsequent implementation:
o Installation Operator;
o Well Operator; or
o Owner of a Non-Production Installation
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Environmental Emergency Response
• The Responsible Person is required by regulation and
permit conditions to report any release or unpermitted
discharge of oil or offshore chemicals to DECC
• Web based oil & gas portal hosts the PON1 reporting tool.
o All releases or unpermitted discharges must be
reported within 6hrs of the incident.
o A release of 1 tonne or more (oil or offshore chemicals)
must be reported to DECC on call inspector within 1hr.
• Applicable incidents must also be reported in accordance with
the Implementing Regulation – 60Kg liquid petroleum
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Environmental Emergency Response
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Environmental Emergency Response
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Environmental Emergency Response
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Environmental Emergency Response
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Environmental Emergency Response
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Environmental Emergency Response
• In the event of any oil release the Responsible Person is
required to implement the OPEP.
• DECC specify 34 areas of OPEP content which include:
• Response Initiation / Direction
• Contractor Mobilisation
• Oil Characteristics
• Training & Exercises
• Worst Case Release
• Modelling
• Cap / Relief Well Mobilisation11 EUAOG Emergency Response Workshop 30 June 2016
Environmental Emergency Response
• DECC provide a 24/7 on call Offshore Environmental
Inspector to respond to any offshore environmental
incidents/urgent permit requests
• DECC have regulatory powers to monitor the Responsible
Persons response to an environmental incident
• DECC utilise an ‘Incident Response Manual’ to detail roles
undertaken, media liaison, ministerial notification etc
• Separate UK legislation creates the role of the Secretary of
States Representative (SOSREP) and provides intervention
powers in the event of potential significant pollution 12 EUAOG Emergency Response Workshop 30 June 2016
Oil Spill Response Effectiveness
• The OSD required IERP is delivered in the UK by updates
to The offshore installations (prevention of fire and
explosion, emergency response) regulations (PFEER) and
the Merchant Shipping (Oil Pollution Preparedness,
Response and Co-operation Convention) regulation
(OPRC)
• One of the new requirements delivered by the amended
OPEP regulations was the inclusion of ‘an estimate of oil
spill response effectiveness’ including consideration of the
environmental conditions as specified in OSD
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Oil Spill Response Effectiveness
• To deliver this requirement for all offshore Oil and Gas
operations Oil & Gas UK contracted Oil Spill Response
Limited to produce guidelines “Oil Spill Response
Effectiveness in UK Waters”
• The guidelines are intended to be used as either an Annex
to the the OPEP or be linked to from the OPEP to provide
the required oil spill effectiveness demonstration.
• The guidelines detail response effectiveness based on
regional weather data and oil type for seven common
response systems.
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Oil Spill Response Effectiveness
• Metocean data specific to operating location and
information regarding ITOPF oil type is used by Operators
to extract the particular oil spill response effectiveness
from the guidance document.
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Oil Spill Response Effectiveness
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Oil Spill Response Effectiveness
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Oil Spill Response Effectiveness
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Seven oil spill response systems that were identified in
consultation with OGUK Members and DECC:
1. Aerial Dispersant
2. In-situ Burn
3. Monitor & Evaluate
4. Natural Dispersion
5. Contain and Recover
6. Shoreline Cleanup
7. Vessel Dispersant
Oil Spill Response Effectiveness – B1
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Aerial Dispersant Contain and Recover
Natural Dispersion
Wind Speed Between 6 kts & 27 kts Less than 20 kts All wind speeds
Visibility More than 3 nm More than 1 nm Does not affect response
Precipitation Does not affect response Does not affect response Does not affect response
Temperature Does not affect response Does not affect response Does not affect response
Tidal State Does not affect response Does not affect response Does not affect response
Current Speed Does not affect response Does not affect response Does not affect response
Ice & Debris N/A in UK Climate N/A in UK Climate N/A in UK Climate
Daylight Dawn to 30 mins before Dusk
Dawn to 30 mins before Dusk
Does not affect response
Wave Height Between 0 m & 4 m Between 0 m and 2.5 m All wave heights
Oil Spill Response Effectiveness – B1
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Oil Spill Response Effectiveness – B1
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Oil Spill Response Effectiveness
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Environmental Data
The environmental (metocean) data provider for the
project was BMT ARGOSS Ltd.
The various metocean data sources are referenced in
the document with the exact locations of grid points
for all parameters.
The operational limitations of the response techniques
and further information on data calculation methods
utilised are detailed in the document.
Inventory of available response equipment
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Second new requirement of the IERP that was
implemented through the amended regulatory regime
• Each OPEP must fully describe the inventory of
available oil spill response equipment available
• The OPEP should reference the register of
equipment held by any contracted oil spill response
provider – Capability statement
• Supplemented by any additional equipment held
not in the register - Installation/field specific
Inventory of available response equipment
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• For any equipment not detailed in the response
providers capability statement the owner/operator
must confirm the following in the OPEP:
i. Details of ownership;
ii. Storage locations;
iii. Transport arrangements to deployment site;
iv. Mode of deployment; and
v. Measures in place to ensure equipment and
procedures are maintained in an operable
condition.
Non Production Installations
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Another key consequence of the amended OPEP
regime is that Non-production installations (NPI) must
hold their own approved OPEP.
• Previously all oil spill response arrangements for
combined/well operations utilising a NPI were
included as addendums to the licenced operators
installation OPEP
• In the new regime each NPI has its own OPEP which
is described in the Safety Case
Non Production Installations
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• The NPI OPEP can be prepared in accordance with a
template developed by IADC in consultation with
DECC
• The NPI OPEP details the non-location specific
aspects of the oil spill response arrangements
(Incident reporting, training, exercises,
arrangements for interface with Well/Installation
Operator etc)
Non Production Installations
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• Updated by the Well/Installation Operator through
a Communications & Interface Plan (CIP) or
Temporary Operations OPEP.
• Reduced review timescale for Combined Operations
OPEP submissions (21 days vs 2 months).
• Potential to use an updated specific section in
existing interface documents to deliver the CIP.
Non Production Installations
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• Schedule of OPEP updates to coincide with
transition of all Safety Cases to the 2015 Safety Case
Regulations.
• Fully updated DECC OPEP guidance published in
January 2015, updated May 2015 & August 2015
following industry engagement.
Further Information
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The Offshore Safety Directive Regulator website can be
found at:
http://www.hse.gov.uk/osdr/
Information provided includes OPEP Guidance and
assessment templates.