Post MC 252: Some
likely Outcomes on Risk,
Hazard, and Response
Rob Cox
Technical Director, IPIECA
Dave Salt
Operations Director, OSR
10/19/10
1
About us....
OGP – International Association of Oil and Gas Producers: represents
upstream industry in front of international organizations and the United
Nations. Oriented towards upstream issue management, production of
engineering and technical standards and promotion of best practice
IPIECA - International Petroleum Industry Environmental Conservation
Association: Represents members and industry on key global
environmental and social issues to international organizations and the
United Nations. Oriented towards strategic and policy issues as well as
best practice
OSR – Oil Spill Response: Industry oil spill response organization funded
by oil industry members of OGP, IPIECA, and other stakeholders. OSR
provides resources (equipment, expertise, centres of excellence) to
respond to oil spills efficiently and effectively on a global basis
10/19/10
2
This presentation
• The new paradigm: drivers for global adoption of a
risk-response model
• Prescriptive vs risk response models
• Adapting the Tiered Response Concept for E&P:
can it be successfully done?
• Examples: Dispersants and subsea injection: an
obvious candidate for R&D and technology
development
10/19/10
3
The new paradigm - 1
• Deepwater Horizon has and will continue to cause changes in regulatory focus
in the US and these will to a greater or lesser extent be emulated in other
jurisdictions
• There is much speculation that these changes might include:
•
increased regulatory requirement on operators
•
requirements to demonstrate the competency of employees
•
increased recordkeeping requirements
•
oversight of operations, maintenance and training
•
independent testing and certification
•
imposition of new standards and management systems
•
a requirement to demonstrate the integrity of containment
•
examination of current liability / compensation schemes for E&P
• At a strategic level, it is becoming clear that there is a need to develop risk and
hazard-based response strategies that are appropriate to E&P operations, yet
which incorporate lessons from the past 30 years of spill response work in the
maritime community
10/19/10
4
Variation in E&P regulatory regimes
NOCS
US
UK
Regulatory
responsibility for safety
Operator
Shared between Operator & regulator
On installation safety case duty holder,
for a well, well operator (1)
Regulators for safety
mgt & resource mgt
Separate
Same body
Separate
HSE (2)
Non-prescriptive
performance based
Prescriptive
Mainly non-prescriptive goal setting (3)
Documented safety
management system
Mandated
Not specified
SCR05
MAR
MHSWR (4)
Compliance with Safety
Management System
Mandated
Not specified
SCR05 (5)
Well safety barriers
Min 2 tested barriers
Not specified
DCR Reg 13 (6)
Riser disconnection
Critical angle
emergency release
Not specified
No prescriptive requirements. Mitigation
as per analysis for major accident
hazards in safety case.
5 yr recertification
Not specified
DCR Reg 13 & 17
SCR05 Reg 19
PUWER Reg 5 & 6(7)
Back up activation
system
Not specified
No prescriptive requirements. Mitigation
as per analysis for major accident
hazards in safety case.
Not specified
No prescriptive requirements. Mitigation
as per analysis for major accident
hazards in safety case. Also
demonstrate compliance with DCR Reg
13 & 17.
Regulatory regime
BOP requirements
Casing shear ram
(DP)
The new paradigm - 2
• US regulator (to some extent) considering risk-response
regime alongside traditional prescriptive model
• Other governments looking to achieve a basis for regulation
• UK – Norway - Europe
• Recognition that all locations do not present same risks as
GoM and therefore do not require same response
• Compatible with the accepted Tiered Response Concept
developed for surface spills/maritime protection
• Scalable to take account of the actual need
• Acceptable to regulators
• Capable of being integrated into E&P management systems,
safety cases, and operations
Tiered response concept
• Used by industry for over thirty years and
is still valid as a response model
• Recognised by governments in
international arena
• Introduced in recognition of probability,
frequency and impact of spills
•
Shipping / terminal / pipeline spills have finite
volume
• Tier definitions not always understood
• Historically, risk of well LoC mitigated
against by use of statistical analysis of low
probability/high impact event on the
probability/impact matrix
Traditional risk response model
Traditional Response Model
Tier
Exploration
1
Utility oil spill
Fuel transfer spill
Drilling mud spills
Drain tank overflows
2
3
National
NationalTier
Tier22
Response
Response
Resources
Resources
••Relevant
Relevant
••Robust
Robust
••Reliable
Reliable
Loss of supply boat fuel
inventory
Total Loss of platform
fuel inventory
Well test spillages
Loss of well
containment
LOSS OF CONTAINMENT EXAMPLES
Production
Transportation
(Including pipelines FSO /
FPSO)
Utility oil spill
Fuel transfer spill
Drilling mud spill
Drain tank overflow
Hose connection spillages
Tank overflows
Loss of supply boat fuel
inventory
STS transfer spillages
Export pipeline spillage
Collision off-take tanker
Platform loss
Loss of well containment
Downstream
(Product distribution)
Utility oil spill
Fuel transfer spill
Drain tank overflow
Hose connection spillages
Tank overflows
Utility oil spills
Transfer spills
Fuel transfer spills
Hose connection spillages
Road tanker spillages
Tank overflows
Collision with Tug / jetty
Loss of cargo containment
in one two tanks
Pipeline total failure
Storage tank failure
Collision product tanker / tug
Hull structural failure
Ship loss ( Collision
/Grounding/ Fire/
Explosion)
Facility loss
Hull structural failure
Ship loss ( Collision /Grounding
Fire/ Explosion)
Credible
CredibleTier
Tier33
response
response
Tiered Response Concept
• E&P spills introduce concepts of
indefinite spill volumes and “resident
risk”
• Nature and location of some E&P
operations can make response difficult
• Reaction could be to define E&P as an
automatic Tier 3 risk
• Need for framework to apply
internationally
• Introduce a Well Risk model in
response
• Should lead to source control plan in
addition to response if deemed
necessary
Revised risk response model
Risk ~ Response Model
Tier
1
2
3
National
NationalTier
Tier22
Response
Response
Resources
Resources
••Relevant
Relevant
••Robust
Robust
••Reliable
Reliable
Exploration
Utility oil spill
Fuel transfer spill
Drilling mud spills
Drain tank overflows
Loss of supply boat fuel
inventory
Total Loss of platform
fuel inventory
Well test spillages
Loss of well
containment
LOSS OF CONTAINMENT EXAMPLES
Production
Transportation
(Including pipelines FSO /
FPSO)
Utility oil spill
Fuel transfer spill
Drilling mud spill
Drain tank overflow
Hose connection spillages
Tank overflows
Loss of supply boat fuel
inventory
STS transfer spillages
Export pipeline spillage
Collision off-take tanker
Platform loss
Loss of well containment
Downstream
(Product distribution)
Utility oil spill
Fuel transfer spill
Drain tank overflow
Hose connection spillages
Tank overflows
Utility oil spills
Transfer spills
Fuel transfer spills
Hose connection spillages
Road tanker spillages
Tank overflows
Collision with Tug / jetty
Loss of cargo containment
in one two tanks
Pipeline total failure
Storage tank failure
Collision product tanker / tug
Hull structural failure
Ship loss ( Collision
/Grounding/ Fire/
Explosion)
Facility loss
Hull structural failure
Ship loss ( Collision /Grounding
Fire/ Explosion)
Credible
CredibleTier
Tier33
response
response
Well
WellRisk
Risk
Assessme
Assessme
nt
nt
Plan
Plan
Additional
AdditionalContainment
Containment
Requirement
Requirement
Source
Source
control
control
plan
plan
Risk Framework
Oil Spill Response
Risk Matrix
Containment Risk
Matrix
High Level
Risk Matrix
Frequency of
Occurrence
3
3
4
5
5
2
2
3
4
5
5
5
1
1
2
3
4
5
1
1
2
3
4
4
Consequence
PEAR
Safety
Environment
Reputation
Finance
Increasing
Risk Assessment
Detail
As Low As Reasonably Practicable
(ALARP) Concept
Limit of Tolerability
Risk
ALARP Principle
to be applied in this
region
Note: A Risk Tolerability Criterion is needed to define the limit of Tolerable Risk
Loss of Containment Risk Factors
•
•
•
•
•
•
•
•
Well Potential Productivity
Water Depth
Sea Conditions
Management System
Compliance
Marine Rig Integrity and
Stability
Design/ Maintenance and
Reliability of Rig Utilities
Rig Mooring System Integrity
Ship Collision Potential
• Drilling and Marine Crew
Competence and Training
• Well Drilling in compliance
with Well Design
• Managed Pressure Systems
Effectiveness (BOP,
Cement/Mud, HPHT )
• Subsea Completion Tree
integrity
• Availability of Drilling
materials and key well
components
• Safety Critical System
Compliance with API, ISO,
NACE, ASME etc
Response Preparedness Risk Factors
•
•
•
•
•
•
•
•
•
•
•
Potential Well Productivity
Oil Type
Well Drilling Difficulty
Well Head/BOP Containment
Intervention Containment Unit
Water Depth
Geographical Location and
distance from response base
Distance from re-supply base
Seasonal/Weather effects on
sea conditions
Distance to National &
International boundaries
Proximity to Navigation
Hazards
• Proximity to vulnerable marine
habitat and spawning area
• Proximity to mammal and bird
habitat and feeding ground
• Proximity to other Offshore
Assets
• Distance/time to Shoreline
• Shoreline Contamination
Length
• Proximity to Coastal Utility
Plant
• Proximity to Private Coastal
Property
• Proximity to Tourist Activity
• Proximity to Fishing Grounds
Oil Spill Risk Matrix
Risk Values represented on matrix as (n)
(3)
Frequency of
Occurrence
(2)
(3)
(2)
(4)
(3)
Tier 2
(1)
(1)
(4)
Tier 3
(3)
Tier 1 (1)
(1)
(4)
(2)
(3)
(5)
(5)
(5
)
(5)
(4)
(5)
(4)
(5)
Consequence (Pollution Severity)
For each Risk Factor, assess the likely frequency
of occurrence with corresponding case specific
Factors must be
pollution severity. These together will give a
considered according risk position on the matrix. The concentration of
to their relevance
risk positions will be illustrative of the collective
in the scenario for
risk impact. Alternatively, the individual risk
which risk is to be
values can be calculated & aggregated to give a
assessed
single overall value of risk to be represented on
the matrix
Risk Factor List
Revised risk response model
Risk ~ Response Model
Tier
1
2
3
National
NationalTier
Tier22
Response
Response
Resources
Resources
••Relevant
Relevant
••Robust
Robust
••Reliable
Reliable
Exploration
Utility oil spill
Fuel transfer spill
Drilling mud spills
Drain tank overflows
Loss of supply boat fuel
inventory
Total Loss of platform
fuel inventory
Well test spillages
Loss of well
containment
LOSS OF CONTAINMENT EXAMPLES
Production
Transportation
(Including pipelines FSO /
FPSO)
Utility oil spill
Fuel transfer spill
Drilling mud spill
Drain tank overflow
Hose connection spillages
Tank overflows
Loss of supply boat fuel
inventory
STS transfer spillages
Export pipeline spillage
Collision off-take tanker
Platform loss
Loss of well containment
Downstream
(Product distribution)
Utility oil spill
Fuel transfer spill
Drain tank overflow
Hose connection spillages
Tank overflows
Utility oil spills
Transfer spills
Fuel transfer spills
Hose connection spillages
Road tanker spillages
Tank overflows
Collision with Tug / jetty
Loss of cargo containment
in one two tanks
Pipeline total failure
Storage tank failure
Collision product tanker / tug
Hull structural failure
Ship loss ( Collision
/Grounding/ Fire/
Explosion)
Facility loss
Hull structural failure
Ship loss ( Collision /Grounding
Fire/ Explosion)
Credible
CredibleTier
Tier33
response
response
Well
WellRisk
Risk
Assessme
Assessme
nt
nt
Plan
Plan
Additional
AdditionalContainment
Containment
Requirement
Requirement
Source
Source
control
control
plan
plan
Containment / Source control plan
• Well risk Containment plan establishes
extent of response requirement
• Is integral to response arrangements
• Identifies level of potential risk
• Source control plan seeks to mitigate:
• Range of possible options
• Does not have to always be at extreme end of
spectrum
Example: dispersants
• Issue of dispersant efficacy in deep water needs
resolution
Dispersants
• In the Sea Empress incident:
•
•
•
•
Approximately 40% evaporated soon after release
Approximately 52% of oil was dispersed into the sea
Approximately 6% was recovered from along 200 km of shoreline
Approximately 2% of oil was recovered at sea
• We have spent 10 years developing dispersant as the
cornerstone of Net Environmental Benefit Analysis
• The potential ramifications are serious
• We need to have confidence that the data is correct
• Is this unique to subsurface spills?
Example: Improved subsea injection
technology likely to be developed
Questions