Oil Pollution Emergency Plan Guidance Impact of · PDF fileOil Pollution Emergency Plan Guidance Impact of Offshore Safety Directive and amended OPRC Regulations 4February 2015

Oil Pollution Emergency Plan Guidance

Impact of Offshore Safety Directive and

amended OPRC Regulations

4 February 2015

DECC Offshore Environmental Inspectorate

Agenda• Why are we here

• Challenges

• Philosophy

• What’s not changed and what has:

• OPEP types and examples

• Review process & transitional arrangements

• Review timeframes & administration process

• Feedback mechanism and updates

• It is not the objective to deal with specific issues at this meeting

2 DECC OPEP Guidance Amendments February 2015

Why are we here?

A number of significant safety and environmental incidents in

recent years focussed EU attention on industry’s preparedness

to respond to such incidents. The Offshore Safety Directive came into being and necessitated a review of the OPRC Regulations

3DECC OPEP Guidance Amendments February 2015

Challenges

• Adoption of ‘multi-operatorship’ approach. Necessitated a significant change to the companies required to hold an OPEP; in what circumstance. This has added complexity

• Time frame – OSD implementation date of July 2015 left limited time to consider OSD, amend OPRC and update OPEP Guidance – projects had to work in tandem which presented ‘interesting’ challenges

• Guidance drafted before OPRC amendments finalised, hence why this Guidance is draft at this stage

• ‘New’ Guidance already completed during 2014 – OSD necessitated a complete re-write


Philosophy

• The OPEP is YOUR response document

• It can be constructed in a manner which reflects YOUR arrangements

• But….it MUST meet the requirements of the amended OPRC Regs and this draft Guidance

• DECC requirements with regard to OPEP structure will be less prescriptive. Our review will follow the Assessment Templates to ensure we are consistent and that all regulatory requirements are met

• The Guidance has been drafted to facilitate a flexible approach where the Regulations allow


What’s NOT Changed?

• Most of it!

• You are already familiar with pretty much everything an OPEP needs to contain

• This is not a major step change to our requirements


What’s Changed?

• Non-Production Installation OPEPs

• Response equipment inventory and effectiveness

• Who needs an OPEP (Well Operator, Installation Operator/Duty Holder)

• OPEP naming conventions (offshore, onshore, consolidated, temp ops, comms and interfaces)

• Spill modelling requirements

• Dispersant standing approvals

• Review timeframes

• DECC administration process


NPI OPEPs

• A must-have to meet the requirements of the OSD

• Endeavoured to keep requirements simple

• Endeavoured to minimise the need for updates

• Working with IADC to construct and agree standard template

• Not just MODUs also applies to flotels, well intervention vessels/barges etc.


Response Equipment Inventory and Effectiveness

• Documents currently being prepared to list equipment inventories and to determine any limitations to the effectiveness of that equipment (weather etc)

• OPEP should reference these documents

• OPEP should also detail any installation specific response equipment which may be available


OPEP Concepts

• Offshore OPEP (Tier 1) – Installation Operator (Duty Holder) / Well Operator / NPI Owner (in part)

• Onshore OPEP (Tier 2/3) – Well Operator

• Consolidated OPEP (Tier 1/2/3) – combination of Installation Operator and Well Operator (they may be the same)


OPEP types

• Installation/Field OPEP – Installation Operator

• Temp Ops OPEP (TOOPEP) – Well Operator

• Comms and Interface Plan – Installation Operator

• NPI OPEP – NPI Owner

• Pipeline OPEP – Pipeline Operator

• Suspended Well – Well Operator


Example - Offshore Installation

Requires:

• ‘offshore’ OPEP from Installation Operator (Installation/Field OPEP – Tier 1 response)

• ‘onshore’ (Tier 2/3) OPEP from Well Operator

• or a ‘consolidated’ (Tier 1/2/3) OPEP (with clear delineation of offshore and onshore aspects – if installation operator and well operator are different, the OPEP must be submitted by the Installation Operator in tandem with their Safety Case)


Example –MODU skidded over offshore installation or

intervening into a connected tied-back well

(Combined Operations)

Requires:

• Installation/Field OPEP and Onshore OPEP or Consolidated OPEP from installation/well operator

• NPI OPEP from NPI owner

• Comms and Interface Plan from

installation operator to update

Installation/Field OPEP and interface

with the NPI and Onshore OPEP


Example – Drilling a remote well , or intervening into

non-connected well (Non-Combined Operations)

Requires:

• Onshore OPEP from

well operator

• TOOPEP from well operator

• NPI OPEP from NPI owner


Oil Spill Modelling

• Modelling requirements have been significantly amended

• This was achieved following detailed consultation with the OSRF modelling group experts

• Industry was consulted separately on the specific guidance section


Dispersant

• You can now request that a specific ‘Standing Approval’ for limited dispersant use be considered when the OPEP is reviewed

• If the information within the OPEP is sufficiently detailed and you’re not in a sensitive area, a SA will be agreed and the use of in-field dispersant can be undertaken without the need for further advice from DECC

• If no SA in place you must contact DECC for advice before dispersants can be applied


DECC Review Process

• We expect that when an OPEP is submitted it will be accompanied by an Assessment Template showing the location of the relevant information within the OPEP

• This will facilitate and expedite the review and will also act as a QA prompt to the submitter of the OPEP

• Templates will ensure a consistent review process

• If no Assessment Template is provided the review may be delayed


DECC Review Process

• There are two ‘categories’ of issues resulting from the OPEP review, a ‘clarification’ and a ‘non-approval issue’

• A clarification will be dealt with by dialogue between the reviewer and the OPEP owner. It will not prevent approval of the OPEP but recommended amendments should be made to the final controlled copy of the OPEP i.e. it is not a Regulatory / Guidance issue

• An OPEP cannot be approved until all NAIs have been resolved satisfactorily. NAIs will be communicated formally to the OPEP owner and the required amendments must be made before the review can continue (e.g. failure to include modelling, incorrect emergency contact details)


Review Timeframes and

Administration Process

• Vast majority of OPEPs retain the usual TWO MONTH review period

• However if a TOOPEP is submitted for operations where an approved ‘onshore’ OPEP exists and the NPI also has an approved OPEP the review period for the TOOPEP will be 21 DAYS (to correspond with the Well Notification submission)

• Similarly if a C&I Plan is submitted for operations where the Installation/Field and the NPI already hold an approved OPEP and there is also an approved ‘onshore’ OPEP the review period for the C&I Plan will be 21 DAYS (to correspond with the combined operations notification)


Transitional Arrangements

• Driven by the Timetable for material changes to Safety Cases as already issued by the Competent Authority

• If operations are ongoing at the time the OPRC amendments come into force then no update to the OPEP is required until the Safety Case for any Installation involved in the operations transitions to the new regime. At such time the OPEP arrangements for the entire operation must comply with the new requirements.

• For operations that commence after the amendments come into force (but before the Safety Case for any installation involved transitions) the current arrangements apply. However operators should consider preparing such plans in accordance with the new regime.


Guidance Comments and Queries

• No formal consultation – simply wasn’t the time hence this meeting

• DECC welcome comments via Inspectorate mailbox

• Identify the section to which the comment relates, describe the issue and propose a solution. Please do not give us a track-changed document

• We will review all comments. The Guidance will be updated (quarterly?) to amend, clarify and improve

• If the comments received necessitate immediate clarification a list of FAQs will be prepared.


Issues Identified to Date

• C&I Plan duplicating the current Bridging Document

• Capability of NPI OPEP to detail specific oil spill response measures

• Specific requirements relating to aerial surveillance capabilities

• Dispersant process

• Clarification of certain definitions e.g. TOOPEP requirement during non combined operations


Moving Forward

We’ve used this opportunity to update the guidance and adjust our philosophy on assessment.

We need industry to work with us to further improve this process.

The Guidance has been drafted to meet the requirements of the regulations but DECC welcomes Industry's constructive comments on ways in which this Guidance can be further developed
