International Offshore Petroleum Environment Regulators

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Priority Issues

 Regulating Oil Spill Preparedness and Response 

149 Source Control Workshop

NOPSEMA, APPEA and the International Offshore Petroleum Regulators (IOPER) coordinated a Source Control Workshop in Australia at Spillcon international oil spill conference held in Perth, Western Australia on May 20th 2019. The one-day workshop focussed on the current state of the industry’s subsea well Source Control Preparedness and Response planning efforts, specifically addressing the delivery and installation of a Capping Stack. 

The workshop brought together global subsea well expertise in E&P operators, international regulators and service providers, to define where efforts are best assigned in pre-planning to minimise the timelines for well intervention in a loss of well control event. Over 120 participants across close to 40 organisations attended the event. 

Presentations throughout the day covered the various aspects and necessary work planning to implement a subsea well source control response and in particular global subsea well response equipment stockpiles, interface and connection variables, fluid dynamics modelling, logistics arrangements and regulatory requirements. Current industry best-practice in planning for a subsea well source control response was also presented in the form of Report 594: “Source Control Emergency Response Planning Guide for Subsea Wells”, developed by the IOGP Subsea Well Response Subcommittee. 

Following the workshop, NOPSEMA initiated a detailed subsea wells source control planning tool in the form of a Response Time Model (RTM) which was adopted and completed by the International Association of Oil and Gas Producers (IOGP). The RTM provides a basis for best practice planning in accordance with Report 594, under a variety of well locations, designs, and characteristics.  IOGP has subsequently produced Report 592 – Subsea Capping Response Time Model Toolkit User Guide to accompany the RTM toolkit and support operators to predict an estimated response timeline for capping a subsea well blowout. Copies of the IOGP Reports and RTM toolkit are available from https://www.iogp.org/bookstore/.

Environment Performance Indicators

IOPER members have agreed to advance an initiative to investigate the development and implementation of a common set of Environmental Performance Indicators (EPIs) with which to measure key areas of environmental performance for the offshore petroleum industries and regulatory regimes in member counties. A common set of EPIs would enhance the ability to share and compare information about the environmental performance relevant to the offshore petroleum industry at an international level. The overarching goal of the initial stage of this project is for IOPER to develop an initial limited set of EPIs that could be used by IOPER members to compare and contrast environmental performance. These EPIs will be developed in consideration of existing schemes in place such as IRF performance measures and the OSPAR and UNEP Global Reporting Initiative.

IOPER members have agreed to take forward a number of work streams on EPIs. Work will be carried out by a multi-national working group chaired by the UK and membership drawn from IOPER member countries. Initial steps for the working group focussed on reviewing existing EPIs, establishing standardised terminology and considering opportunities and constraints associated with the different regulatory regimes that operate in member countries. No decision has been made yet regarding implementation of EPIs, however it is possible that some member countries will need to consider amending arrangements for reporting and collection of performance data to ensure the necessary consistency. A universal data collection template was  presented to members at the IOPER mid-year meeting (May  2016) with NOPSEMA and UK OPRED trialling 2015 data collection using this template. Refinements have been made to the template and this was rolled  out to other IOPER members for data collection  in 2016/17.

Joint Industry Workshop on Oil Spill Preparedness and Response

In May, 2016 the International Offshore Petroleum Regulators (IOPER) joined forces with the Australian Petroleum Production and Exploration Association (APPEA) to organise and stage a joint regulator/ industry workshop on the oil spill preparedness topic of ‘How Much is Enough?’. The half-day workshop was held in conjunction with the Spillcon conference in Perth, Western Australia. During the well-received workshop industry and government stakeholders working in oil spill preparedness and response discussed national and international perspectives on how much preparedness and response is appropriate in the context of oil spill risks from offshore oil and gas. Topics discussed included the key role of risk assessment in determining response need, the development of tactical response plans, the use of semi-quantitative approaches to measuring capability, and the role that the ALARP principle plays in the Australian context.

The workshop furthered work undertaken by IOPER members to develop a number of internationally-recognised ‘guiding principles’ for regulating oil spill response preparedness in the offshore oil and gas industry. These aim to ensure proper and systematic risk identification and management processes and drive identification, implementation and maintenance of the right spill planning, preparedness and response arrangements. These are described in the Guiding Principles document and its accompanying introduction.

Public Consultation and Decision Making

IOPER members have agreed to explore opportunities and challenges in the area of public consultation and decision making for environment regulatory approaches. This is a key area of environmental management for offshore petroleum industries and regulatory regimes in member counties.

Sharing perspectives on this topic will enhance the ability to compare information about the effectiveness of and return on effort. Surveys of IOPER members on this topic have shown that all jurisdictions have mechanisms in place in legislation to generate appropriate disclosure and opportunities for affected or interested parties to be consulted in the planning and implementation stages of offshore petroleum operations. The means by which informed consultation is provided often vary given the different scope, legal framework and scale of offshore petroleum operations in each jurisdiction. 

Further exploration of this topic will focus on the degree to which public consultation mechanisms efficiently and effectively effect and improve environmental outcomes. The initiative may also lead to better understanding where public input and other decision making efficiencies could be achieved.

Members have agreed to further project work to identify areas of highest return and will continue to share experiences and good practices.

Environmental Impact Research Collaboration Opportunities

IOPER members discussed how increasingly complex pressures on the marine environment from petroleum industry activities require regulators to consider what are the priority areas for improving scientific understanding of environmental impacts, how they can be managed and how environmental performance can be measured.

IOPER members have agreed to collaborate on identifying the various ways that each of the different jurisdictions aim to manage or minimise impacts from oil and gas activities and improve understanding in areas of scientific uncertainty regarding environmental impacts, with the aim of identifying where collaboration between the jurisdictions may lead to more cost effective or valuable research outcomes.

Enforcement Tool Research

Regulatory theory suggests that successful regulators have a sophisticated understanding of the nature of the risk that is being regulated, the regulated parties, and the changing regulated environment. In the context of the offshore petroleum industry, the possible research areas include:

  • Understanding the regulated companies
  • Understanding the capacity and role of the regulator
  • Understanding the changing environment
  • Understanding the quality and effect of regulation

Practical areas where research might be useful include:

  • Enforcement tools
  • Information and targeting
  • Transparency

Members have agreed to initiate a research project on enforcement tools using a survey and to share a draft of the survey with members for feedback.

Decommissioning

General challenges associated with decommissioning include:

  • Non-compliance (e.g. if not completed, poses risk to safety and environment).
  • Lack of financial solvency, leading to lessees being unable to finance suitable decommissioning.
  • Removal of habitat formed around structures during decommissioning.
  • Environmental damage caused during the decommissioning activities (such as fish kills associated with explosive removal of platforms).
  • Extreme weather events that damage structures and increase the cost of decommissioning.

IOPER members noted that many challenges are common and the issue is addressed differently in each jurisdiction. It was agreed that information on how environmental impacts as a result of removal are considered in respective jurisdictions would be useful to share.

BOEM has prepared a list of scholarly articles on the environmental impacts of decommissioning. These articles were identified using energy and environmental databases with references from peer reviewed journals, industry publications, trade magazines, and workshop proceedings. In all, 38 relevant articles and other sources such as books were identified. A copy of the document is available here.

 

 
 

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