ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA

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ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
2021 - ISSUE 2

                 ENSURING RESPONSIBLE
                 DECOMMISSIONING
                 Responsible decommissioning
                 means planning for
                 safe decommissioning
                 right from the design stage
                 page 08

                                      nopsema.gov.au
ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
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STRATEGIC COMPLIANCE
FOCUS AREAS FOR 2021                                          CONTACT DETAILS
                                                              Head office — Perth
PREVENTING MAJOR
                                                              Level 8, 58 Mounts Bay Road
ACCIDENT EVENTS
                                                              Western Australia
PREVENTING LOSS                                               P: +61 (0) 8 6188 8700
OF WELL CONTROL
                                                              GPO Box 2568
EFFECTIVE OIL POLLUTION                                       Perth WA 6001
EMERGENCY PREPAREDNESS
                                                              Published in July 2021
RESPONSIBLE ASSET
STEWARDSHIP

The information provided in this publication is intended to provide its reader with general information only and should
not be relied on as advice on law, nor treated as a substitute for legal advice in any situation. NOPSEMA’s assessment
of regulatory permissioning documents, compliance monitoring, and enforcement activities, are undertaken in
accordance with the relevant legislation and associated regulations.
ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
THE REGULATOR
In this edition

04                  08                   18
MESSAGE FROM THE    ENSURING             CONTINUAL
CHIEF EXECUTIVE     RESPONSIBLE          IMPROVEMENT IN OIL
OFFICER             DECOMMISSIONING      SPILL RESPONSE

06                                       20
HOT SURFACES POSE                        2020 KEY
HYDROCARBON                              PERFORMANCE DATA
IGNITION RISK
                    12                   21
07                  IMPROVING
                    OFFSHORE CRANE
                                         2020 OFFSHORE
INSPECTIONS                              INDUSTRY ACTIVITY
                    SAFETY
TO INCREASE FOCUS
ON HIGHEST RISK
                    13                   22
                                         HELP US IMPROVE
                    APPEA FOCUS
                                         OUR WEBSITE

                    14
                    IMPROVING
                    INTERACTIONS
                    BETWEEN
                    COMMERCIAL
                    FISHERIES AND
                    SEISMIC PROPONENTS
ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
MESSAGE FROM THE
  CHIEF EXECUTIVE
  OFFICER
  Recently, I was pleased to be invited to the CEO Safety Forum
  held during the APPEA 2021 Conference to address industry leaders
  on mental health and other current NOPSEMA priorities.

  Mental health is something we are all         At NOPSEMA, we understand border
  grappling with during this pandemic           closures, travel restrictions and
  and the offshore oil and gas industry is      quarantine requirements have forced
  no different. We are seeing heightened        the industry to implement changes
  anxiety and tension offshore that has         that will reduce the risk of COVID-19
  the potential to affect attention to detail   transmission. Industry must now also
  and overall performance. When you             ensure the psychosocial effects of these
  add workers spending time in isolation,       changes are being managed to minimise
  working longer swing patterns and             the potential for longer-term mental
  dealing with extended separations from        health effects on workers.
  loved ones, it is easy to understand
                                                Industry should also be cognisant of
  the heightened risk to personal health,
                                                the impact that travel restrictions may
  process safety and the potential for
                                                have on workforce competencies in
  major accident events to occur.
                                                fields such as the assessment and
                                                maintenance of structural integrity.
                                                NOPSEMA has recently increased its
                                                focus on maintenance, particularly
                                                of ageing assets and how they are
                                                managed in the late-life stage.
     We are seeing
     heightened anxiety                         Timely and appropriate maintenance is a
                                                key control in the prevention of harm and
     and tension offshore                       protection of the environment. Continued
     that has the potential                     maintenance is also a critical part of
     to affect attention                        planning for decommissioning. Our Head
                                                of Safety and Integrity, Derrick O’Keeffe,
     to detail and overall
                                                addressed this point at the APPEA
     performance.                               Conference in his presentation on
                                                Deferred Maintenance – A Major
                                                Industry Challenge. Over the next few
                                                years, NOPSEMA will be monitoring
                                                duty holders closely to ensure they are
                                                undertaking the required inspection,
                                                monitoring, maintenance and repair
                                                processes in a timely manner.

4 THE REGULATOR ISSUE 2 2021
ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
Another key priority for NOPSEMA is safe and     From discussion at the APPEA 2021
responsible decommissioning. The Australian      Conference it was clear that industry
Government has confirmed its expectation         leaders are increasing their focus on the
that NOPSEMA take a heightened interest          growing number of assets in Australia that
in late life assets and that we apply the full   are approaching end of life and requiring
range of our compliance powers to ensure         decommissioning. The willingness of these
appropriate decommissioning when facilities      leaders to adopt a collaborative approach was
reach their end of life. NOPSEMA has released    encouraging and NOPSEMA looks forward
several guidance documents to assist industry    to working with them to ensure facilities are
in complying with their decommissioning          decommissioned in a safe and environmentally
obligations. These documents include a           responsible manner.
regulatory policy outlining requirements and
                                                 I trust you find this latest edition of
expectations for the maintenance and removal
                                                 The Regulator informative.
of property.
NOPSEMA has also published a
decommissioning compliance strategy
and plan to clarify how we work with duty
holders to assist them in complying with their
decommissioning obligations and the types
of compliance actions they can expect where      Stuart Smith
compliance cannot be demonstrated. Further       Chief Executive Officer
compliance action on decommissioning can be
expected over the coming year.

                                                                         THE REGULATOR ISSUE 2 2021   5
ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
HOT SURFACES POSE
PREVENTING MAJOR
 ACCIDENT EVENTS

                   HYDROCARBON IGNITION RISK
                   Offshore oil and gas facilities typically have power generation
                   and processing equipment that will generate or contain
                   significant heat, and consequently hot surfaces. An exposed
                   hot surface can be an ignition source if there were to be a leak
                   of flammable hydrocarbons. This could potentially lead to a
                   major accident event such as fire or explosion and loss of life.
                   The risk of such a catastrophic event is real, significant, and
                   cannot be ignored.

                   NOPSEMA has received multiple            Where a hot surface exceeds the
                   notifications of dangerous               maximum temperature specified in
                   occurrences from hot surfaces            the performance standard, in line
                   associated with equipment including      with the safety case or an industry
                   turbines, steam systems, and boilers.    standard, the duty holder must
                   Each occurrence was unique due to        immediately take steps to mitigate
                   the specific type, design, and layout    or reduce the risk of ignition. This
                   of equipment, as well as the design      could include shutting down the
                   standards applied and the types of       equipment, reducing production,
                   hydrocarbons at the facility. The risk   delaying or suspending any high-
                   of a major accident event was the        risk activities, undertaking a formal
                   common factor.                           risk assessment, more dispersion
                                                            modelling, increasing the frequency
                   To ensure the risk of hydrocarbons
                                                            of assurance activities, and/or
                   igniting from exposure to a hot
                                                            re-engineering the equipment.
                   surface can be managed, duty
                   holders should, at the design            In May, NOPSEMA released a draft
                   phase of their facility, determine       information paper to raise awareness
                   the maximum surface temperature          and highlight appropriate approaches
                   of equipment during normal and           to managing the risk of hydrocarbons
                   abnormal conditions. Hotter-than-        igniting from exposure to hot surfaces.
                   expected surface temperatures may        The paper presents our observations
                   occur during operational life for        and expectations around general risk
                   several reasons, for example due to      management approaches, based
                   degradation of insulation material.      on industry standards and relevant
                                                            good industry practice to ensure that
                   In this case, duty holders must have
                                                            equipment at a facility is safe and
                   performance standards in place that
                                                            without risk to health.
                   define the assurance activities that
                   will control, manage, and monitor the    The draft Management of hot surface
                   risk of hydrocarbons igniting from       information paper is available on
                   hot surfaces.                            our website. Currently, NOPSEMA is
                                                            considering feedback provided by
                                                            industry and other stakeholders in
                                                            finalising the paper.

         6 THE REGULATOR ISSUE 2 2021
ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
INSPECTIONS TO INCREASE
FOCUS ON HIGHEST RISK
NOPSEMA is changing how it programs its inspections, spending less time
inspecting activities where the duty holder has demonstrated compliance and
more time inspecting higher risk activities.

While NOPSEMA’s regulatory processes have           to own the risks and must address issues and
long been regarded as world-class, recent           non-compliance identified by NOPSEMA in a
events including the COVID-19 pandemic, the         timely manner.
decommissioning of the Northern Endeavour,
                                                    NOPSEMA will continue to issue
and the Australian Government’s deregulation
                                                    recommendations to set out the actions it
agenda has prompted NOPSEMA to change its
                                                    expects duty holders to take to address issues
approach to ensure we remain effective.
                                                    and non-compliance. Recommendations are
A more flexible and dynamic approach to             issued where the issue or non-compliance is of a
inspections will improve NOPSEMA’s efficiency       nature that can be managed by the duty holder,
by redirecting resources to monitor the             does not pose an immediate or significant threat,
higher risk activities and reduce regulatory        and is not a serious or blatant contravention
burden on duty holders that have already            of the law. NOPSEMA will follow-up all
demonstrated compliance.                            recommendations and take enforcement action
                                                    where warranted.
NOPSEMA will maintain a ‘baseline’ frequency
of risk-based inspections, for example, we will     Further changes are being considered including
continue to inspect activities where the duty       greater flexibility for duty holders to manage
holder has demonstrated compliance, but the         risks and increased accountability to address
activity and oil type pose a higher risk.           the cause(s) of non-compliance identified by
                                                    NOPSEMA. In the coming months, NOPSEMA
NOPSEMA will also now include formal
                                                    will publish a revised Inspection policy for
conclusions in its inspection reports to
                                                    comment detailing the forthcoming changes.
ensure our findings and observations are
communicated clearly. Duty holders will continue

                                           IN
                                                  SP
                                                       EC
                                                          T   IO
                                                                   N

                  PROG
                                 RAM M
                                                   ING
                                                                          THE REGULATOR ISSUE 2 2021    7
ENSURING RESPONSIBLE DECOMMISSIONING - Responsible decommissioning means planning for safe decommissioning right from the design stage - NOPSEMA
RESPONSIBLE ASSET
     STEWARDSHIP

          8 THE REGULATOR ISSUE 2 2021
ENSURING RESPONSIBLE
DECOMMISSIONING
While the decommissioning of offshore oil and gas facilities
has been a legal obligation in Australia since the late 1960s,
only a handful of facilities have been decommissioned in
that time. Now, more than half of the facilities regulated
by NOPSEMA are more than 20 years old, some more than
50 years, and at least 13 have ceased production. Many of
these facilities will need to be decommissioned over the
next five to ten years.

Responsible decommissioning,               To assist duty holders in
that is safe and cost-efficient, is        understanding and complying with
challenged when duty holders leave         their decommissioning obligations
their planning for decommissioning         NOPSEMA has published several
to the end of a facilities life.           guidance documents. This included
                                           a Section 572 Maintenance and
“Responsible decommissioning
                                           removal of property regulatory
means planning for safe
                                           policy in 2020 that outlined all of
decommissioning right from the
                                           the pre-existing decommissioning
design stage, and well before facilities
                                           requirements and NOPSEMA’s
have been installed” said NOPSEMA’s
                                           expectations on how they should
Head of Environment and
                                           be met.
Decommissioning, Cameron Grebe.
In 2019, the Minister for Resources
and Northern Australia issued
a Statement of Expectations to
NOPSEMA in which he highlighted
the need for heightened oversight
                                              Responsible
of duty holder compliance with                decommissioning
their decommissioning obligations.            means planning for safe
NOPSEMA subsequently
                                              decommissioning right
increased its promotion and
advice, compliance monitoring,                from the design stage
and enforcement activities
for decommissioning.

                                                      THE REGULATOR ISSUE 2 2021   9
Recently, NOPSEMA published           At NOPSEMA, we recognise the
                       a five-year Decommissioning           increasing pressure placed on
                       Compliance Strategy to communicate    duty holders to reduce costs as
                       how it would work with duty holders   production declines, however, it
                       to ensure timely and responsible      remains a legal requirement for duty
                       planning and implementation of        holders to maintain all property
                       decommissioning activities.           and equipment in good condition
                                                             and repair. It is unacceptable for
                       "Our goal is to have
                                                             duty holders to allow their disused
                       decommissioning plans in place
                                                             property and equipment to degrade
                       by 2023 for all facilities where
                                                             to a point where it becomes too
                       property and equipment is no longer
                                                             dangerous to remove or otherwise
                       in use, and by 2025, property and
                                                             safely decommission.
                       equipment should be removed within
                       five years of not being used and      Recently, NOPSEMA has found
                       wells permanently abandoned within    several cases of corrosion and
                       three years of ceasing production"    other structural damage, particularly
                       said NOPSEMA’s Decommissioning        at ageing assets. Cases such as
                       Manager, David Christensen.           this will challenge a duty holders’
                                                             ability to decommission responsibly.
                       In support of the strategy,
                                                             NOPSEMA will be closely monitoring
                       NOPSEMA has also published a
                                                             duty holders to ensure they are
                       Decommissioning Compliance Plan.
                                                             carrying out the required inspection,
                       The plan identifies the types of
                                                             monitoring, maintenance, and
                       compliance actions duty holders can
                                                             repair processes.
                       expect NOPSEMA to consider
                       depending on several factors.
                       This includes the length of time
                       a field has been in permanent
                       state of non-production, the level       NOPSEMA has found
                       of planning and preparation for          several cases of
                       decommissioning in current, or
                       under revision, permissioning            corrosion and other
                       documents, and the level of              structural damage
                       integrity issues likely to limit
                       options for decommissioning.

10 THE REGULATOR ISSUE 2 2021
“In taking appropriate and
                                           proportionate compliance action,
                                           NOPSEMA seeks to further clarify to
   NOPSEMA seeks                           duty holders their decommissioning
   to further clarify to                   obligations and NOPSEMA’s
   duty holders their                      expectations,” said Mr Christensen.

   decommissioning                         Over the next year, NOPSEMA
                                           will engage with the duty holders
   obligations and                         we have identified as requiring
   NOPSEMA’s                               a higher or moderate level of
   expectations                            regulatory oversight to discuss
                                           their compliance with their
                                           decommissioning obligations. In
                                           most cases, duty holders should
NOPSEMA has already issued                 expect lower-level compliance action
directions for Eni’s Woollybutt field      to be taken, for example NOPSEMA
and Woodside’s Enfield, and to             requesting revisions to accepted
Exxon Mobil (Esso) for multiple non-       permissioning documents.
producing facilities in the Bass Strait.
                                           “Each case will be unique with
The directions set clear timeframes        a range of circumstances and
for plugging and abandoning wells,         considerations that we will need
removing property and equipment,           to take into account before taking
protecting natural resources, and          any type of compliance action,”
making good any damage to                  said Mr Christensen.
the seabed. The directions also
                                           To learn more about NOPSEMA’s
require property and equipment to
                                           expectations and how to comply with
be maintained in good condition
                                           your decommissioning obligations
and repair so that it may be safely
                                           please visit our website.
removed or, where NOPSEMA
approves an alternative solution such
as repurposing, remain on location.

                                                      THE REGULATOR ISSUE 2 2021   11
IMPROVING
PREVENTING MAJOR
 ACCIDENT EVENTS

                   OFFSHORE
                   CRANE SAFETY
                   Since mid-2020, NOPSEMA has observed a significant
                   increase in reports of dangerous occurrences relating to
                   offshore cranes. Following 29 investigations, NOPSEMA has
                   highlighted crane safety as an area of increased risk and
                   hence a priority for compliance monitoring.

                   Across 35 fixed facilities regulated by             These findings indicated that the crane was
                   NOPSEMA, there are 67 pedestal cranes,              operated in a condition that increased the
                   as well as several other types of cranes in         potential for failure, placing workers at risk.
                   operation. It is clear that a crane is both
                                                                       During NOPSEMA’s investigation, the duty
                   an essential piece of equipment on many
                                                                       holder took the crane out of operation
                   facilities, and also one of inherent risk, making
                                                                       and it remains out of operation to date.
                   it important for duty holders to be mindful of
                                                                       NOPSEMA issued an improvement notice
                   operational pressures on their decision-making
                                                                       to ensure the duty holder completed all the
                   when it comes to crane operations and the
                                                                       necessary steps to reduce risk to as low as
                   consequences for workforce safety.
                                                                       reasonably practicable.
                   Globally, the offshore industry has seen
                                                                       Further to the safety bulletin, NOPSEMA is
                   many catastrophic incidents involving
                                                                       preparing to publish an Improving Offshore
                   cranes collapsing or loads being dropped
                                                                       Crane Safety discussion paper outlining its
                   resulting in death and serious injury, damage
                                                                       observations and expectations. This includes
                   to equipment and infrastructure, and the
                                                                       common failures identified across all reported
                   release of hydrocarbons with safety and
                                                                       dangerous occurrences such as management
                   environmental consequences.
                                                                       of corrective maintenance, competency of
                   In May 20201, NOPSEMA issued the Safe               personnel, and applying lessons learned.
                   operation of degraded cranes with reduced
                                                                       NOPSEMA hosted a workshop with industry
                   capacity safety bulletin in response to three
                                                                       duty holders and crane subject matter experts
                   incidents involving cranes that were being
                                                                       in July to provide insights into the contributory,
                   operated with degraded capabilities.
                                                                       causal and other relevant factors of the recent
                   In one of the more concerning incidents, the        crane-related dangerous occurrences and to
                   duty holder had failed to use its management of     identify leading practices and opportunities
                   change procedures to assess the risk of using       for improvement. NOPSEMA's crane safety
                   a crane with structural corrosion, failed to use    presentation, which was delivered at the
                   any recognised standard during a load test of       workshop, can be viewed on our website.
                   that crane and failed to examine the crane after
                   the load test before putting the crane back
                   into operation at a reduced lifting capacity.

      12 THE REGULATOR ISSUE 2 2021
APPEA FOCUS
NOPSEMA was pleased to be able to host a           With blue hydrogen and carbon capture and
booth at this year’s very successful APPEA         storage both prominent on the agenda it seems
conference in Perth. The largest in-person         the oil and gas industry is well positioned
conference in Australia since COVID appeared       to support Australia’s energy supply and
in early 2019 ran smoothly, and it was great       contribute to global targets to meet net zero
to see a diverse range of participants in          by 2050.
the plenary sessions. Plenty of delegates
                                                   Our Head of Safety and Integrity,
took the opportunity to come and ask
                                                   Derrick O’Keeffe, presented on industry’s
questions or chat to the NOPSEMA team.
                                                   response to COVID-19 and what comes next,
Our new decommissioning brochure was
                                                   as well as deferred maintenance and the impact
especially popular.
                                                   it has on safety. Both presentations can be
The focus of the conference was squarely           viewed on our website.
on the role of oil and gas in a net zero future.
                                                   Our CEO, Stuart Smith, spoke at the CEO’s
There were some excellent presentations
                                                   safety forum about mental health and the
that demonstrated a willingness to embrace
                                                   importance of duty holders working with the
the shift in thinking required to position the
                                                   offshore workforce to address this increasingly
oil and gas industry as a key player in global
                                                   challenging issue, particularly in the context of
emissions reductions.
                                                   the pandemic and its ongoing impacts.
In the opening plenary, Prime Minister Scott
                                                   Decommissioning was the theme of several
Morrison reaffirmed the importance of gas as
                                                   sessions with industry showing good signs
a driver of Australia’s post-COVID economic
                                                   of preparedness for the significant volume of
recovery, and former Chief Scientist Alan Finkel
                                                   decommissioning work that will be required
confirmed the critical role for gas, not only
                                                   in Australia over the next 10 years. It was
as a transition fuel, but as one of the many
                                                   great to see industry showing a desire to
ingredients required to produce high volume
                                                   take a collaborative approach to tackling the
and reliable renewable energy supply.
                                                   decommissioning liability.

                                                                         THE REGULATOR ISSUE 2 2021    13
IMPROVING INTERACTIONS
   BETWEEN COMMERCIAL
   FISHERIES AND SEISMIC
   PROPONENTS
   Where a seismic survey is proposed in, or adjacent to, important fishing
   grounds, conflict between the party conducting the seismic survey and
   commercial fishers often arises. Managing this conflict can be difficult as
   each industry has a ‘licence to operate’ in the marine area but neither
   has priority usage. In the absence of a formal framework to guide the
   interactions between them, issues have to be identified and resolved through
   case-by-case assessment under the OPGGS Environment Regulations which
   creates tensions and burden for parties required to be consulted.

   Recently, the Senate Inquiry into       Seismic proponents expressed
   the Impacts of Seismic Testing on       concern about how difficult it is to
   Fisheries and the Marine Environment    access fisheries information and
   released its final report. NOPSEMA      other relevant evidence to inform
   welcomed the inquiry, actively taking   their evaluation and management of
   part by preparing a submission          impacts to commercial fisheries and
   and attending a hearing via video       their target species, and how that
   conference to provide evidence.         prolongs the assessment of their
   NOPSEMA’s submission has been           environment plan.
   described as being both ‘excellent
   and very comprehensive’.
   Part of the inquiry’s focus was
   on understanding the conflict              without good
   between seismic survey
                                              relationships... it is
   proponents and commercial
   fishers. Stakeholders representing         unlikely such conflict
   commercial fisheries expressed             can be appropriately
   concern about the impact of                addressed by
   high intensity sound emissions
   on commercially important fish
                                              NOPSEMA and
   and invertebrate species and               the Environment
   subsequent disruption of their             Regulations alone.
   fishing operations.

14 THE REGULATOR ISSUE 2 2021
When it comes to this type of              This work initiated the establishment
conflict, a lot of attention is directed   of a collaborative forum, chaired by
at the regulatory process, but             DISER aimed at developing a policy
without good relationships or              framework with new initiatives to
proper consideration of genuine            conflict and improving cooperation
concerns, it is unlikely such conflict     between seismic survey proponents
can be appropriately addressed by          and commercial fishers. The policy
NOPSEMA and the Environment                framework concept is adopted from
Regulations alone.                         a similar framework successfully
                                           implemented in Norway and
NOPSEMA has been supporting the
                                           identified by both industries as a
Department of Industry, Science,
                                           leading practice.
Energy and Resources (DISER)
and the Department of Agriculture,         Key Australian commercial fishing
Water and the Environment (DAWE)           groups and offshore petroleum peak
in facilitating the two industries         bodies (and their members) are
to explore and agree on more               supportive of the project and have
collaborative solutions.                   agreed to collaborate in agreeing
                                           specific measures within the
                                           framework to remove some of the
                                           points of conflict and burden in the
                                           individual survey approvals.

                                                                           THE REGULATOR ISSUE 2 2021   15
Currently, this collaboration includes
                                                 developing guidance for strategic
                                                 and operational engagement
                                                 between the industries, a standard
                                                 loss adjustment protocol that enables
                                                 fishers to make evidence-based
                                                 claims for compensation for
                                                 financial losses as a direct result of a
                                                 seismic survey and other measures
                                                 the industries identify and agree
                                                 as helpful.
                                                 Ultimately it is up to the industries to
                                                 agree on solutions that address their
                                                 respective needs. The case-by-case
                          Ultimately it is up    assessment and approval by
                          to the industries to   NOPSEMA for individual seismic
                                                 surveys will remain and issues that
                          agree on solutions
                                                 cannot be resolved by the industries
                          that address their     will continue to arise through the
                          respective needs       individual assessments.
                                                 The seismic inquiry also focussed on
                                                 scientific uncertainty about the short
                                                 and long-term effects of noise on
                                                 marine life. To address the challenges
                                                 presented by scientific uncertainty,
                                                 NOPSEMA requires seismic
                                                 proponents to implement a thorough
                                                 environmental impact assessment
                                                 process with scientifically sound
                                                 application of the best available
                                                 data. Where a gap in data creates
                                                 uncertainty as to whether impacts
                                                 will be of an acceptable level, a
                                                 range of measures are required

16 THE REGULATOR ISSUE 2 2021
to address this. This may
include taking a precautionary
approach by excluding sensitive
locations and/or times of                  NOPSEMA supports
year, implementing adaptive                the formation of
management to respond to                   a collaborative
information gathered during
a survey, and/or validating                research framework
impact predictions through                 in Australia
environmental monitoring.
The measures required to address
scientific uncertainty can add
                                        NOPSEMA supports the formation of
significant cost to a seismic
                                        a collaborative research framework in
survey and, at times, be a barrier to
                                        Australia for the offshore petroleum
the objectives of the survey being
                                        industry. A well-designed framework
achieved. There are a number of
                                        has the potential to produce research
examples in Australia and around
                                        that will support evidence-based
the world where these challenges
                                        environmental impact assessments
are being addressed through
                                        and improve environmental
collaborative research frameworks.
                                        management outcomes. The
For example, the Fisheries Research
                                        mechanism by which such a
and Development Corporation, the
                                        framework is funded and governed
Influence of Man-made Structures on
                                        will need detailed analysis and
the Ecosystem in the North Sea and
                                        consideration of the lessons learned
the IOGP-JIP Sound and Marine Life
                                        from similar frameworks.
Program. These frameworks have
been successful in answering key
environmental impact assessment
questions, without imposing
unreasonable costs on proponents.

                                                                       THE REGULATOR ISSUE 2 2021   17
EFFECTIVE OIL
POLLUTION EMERGENCY
       PREPAREDNESS

                        CONTINUAL IMPROVEMENT
                        IN OIL SPILL RESPONSE
                        A central tenet of outcomes-based regulation is that of continual improvement.
                        What this means is that the industry must regularly examine controls and
                        arrangements to identify and implement possible improvements, such as
                        adopting new technology, services, procedures, and practices, to meet increasing
                        community expectations.

                        Following the Montara and Macondo                 To ensure the Australian industry maintained
                        disasters, the global oil and gas industry        its focus on continual improvement,
                        demonstrated its capacity for continual           NOPSEMA established oil pollution emergency
                        improvement by implementing a suite of joint      preparedness as one of its strategic
                        industry projects to improve oil spill response   compliance focus areas. We examined options
                        capability. These projects brought substantial    for improvement in oil spill preparedness
                        developments across globally pre-positioned       and capability and worked with the industry
                        capping stacks and ancillary equipment,           to implement the improvements. In 2017,
                        dispersant stockpiles, and a range of other       NOPSEMA established the Spill Risk
                        capability and preparedness measures.             Cooperative Forum (SRCF) to provide
                                                                          titleholders a forum where they could
                                                                          explore cooperative solutions for improved

            18 THE REGULATOR ISSUE 2 2021
preparedness and response measures,                The learnings from the workshop led
solutions that would otherwise be out of reach     NOPSEMA and IOPER to collaborate with
for a single titleholder.                          the International Association of Oil & Gas
                                                   Producers (IOGP) to develop the Response
The success of the SRCF contributed to APPEA
                                                   Time Model (RTM). The RTM is a tool designed
forming an industry Oil Spill Preparedness
                                                   to assist titleholders in identifying the tasks
& Response Working Group (OSPRWG) to
                                                   and predicting the timelines for capping a well
further develop and implement improvement
                                                   blowout. The IOGP published Report 592;
options. NOPSEMA recently engaged with the
                                                   a toolkit for the RTM to guide planning of timely
OSPRWG while undertaking a revision of its
                                                   source control emergency response. The report
Oil Pollution Risk Management guidance note.
                                                   was co-presented by NOPSEMA and IOGP at
The revision was undertaken to incorporate
                                                   the recent International Oil Spill Conference to
industry feedback and improve the clarity and
                                                   disseminate the knowledge and the RTM to the
effectiveness of the guidance. The guidance
                                                   global industry.
note is now available for comment on
our website and NOPSEMA encourages all of          Through 2020–21, NOPSEMA and the APPEA
its stakeholders to provide feedback.              Drilling Industry Steering Committee (DISC)
                                                   worked to embed the learnings of the RTM
Internationally, NOPSEMA took a leading role
                                                   into the Australian offshore petroleum industry.
as a member of the International Offshore
                                                   Recently, NOPSEMA and IOGP presented the
Petroleum Environment Regulators (IOPER)
                                                   work at the APPEA conference and announced
group in establishing their Oil Spill Working
                                                   the release of the APPEA Australian Offshore
Group. From 2018–20, NOPSEMA’s Drilling
                                                   Titleholders Source Control guideline and
and Spill Risk Manager, Rhys Jones, chaired
                                                   the NOPSEMA Source Control Planning and
the group and led a work stream focussed
                                                   Procedures information paper. The paper
on the timelines of source control response.
                                                   clarifies NOPSEMA’s expectations for source
Mr Jones reflected on the group’s work in
                                                   control content within an environment plan,
leading improvement in oil spill response at the
                                                   well operations management plan, and
plenary session of the recent International Oil
                                                   safety case, as well as a source control
Spill Conference.
                                                   emergency response plans (SCERP), which is
“Across the industry, it was clear to us that      an operational response plan developed and
response planning was inconsistent and the         maintained by titleholders. APPEA’s guideline
logistics capability to deploy wasn’t uniformly    provides the industry with further details of the
understood. We saw an opportunity to improve       SCERP content requirements, consistent with
the timeframe for deploying a capping stack        IOGP guidance for source control.
and source control equipment to respond to a
                                                   Moving forward, NOPSEMA sees many more
loss of well control,” said Mr Jones.
                                                   opportunities for continual improvement. This
With that goal, NOPSEMA and IOPER partnered        includes testing of global oil spill response
with APPEA in 2019 to host a Source Control        capability to ensure it is operationally ready
Workshop. The workshop was attended by             and improving arrangements for effective and
120 participants from nearly 40 organisations      efficient incident management control of a
who shared valuable knowledge on the tasks         large-scale oil spill response. NOPSEMA will
required to deploy and install a capping stack     continue to focus on oil pollution emergency
and where efforts should be directed to improve    preparedness and work with the industry,
timeliness and effectiveness.                      technical authorities, and international
                                                   regulatory counterparts to drive improvement.

                                                                         THE REGULATOR ISSUE 2 2021    19
2020 KEY PERFORMANCE DATA

              177                              561                          36
         INSPECTIONS                                                ENFORCEMENT
                                        INVESTIGATIONS
                                                                      ACTIONS

                        1055                                         387
                        STAKEHOLDER                                  ASSESSMENTS
                        MEETINGS

                   8.5million                        Completed assessments included:
                                                     86 occupational health and safety
                   TOTAL HOURS                       42 environmental management
                   WORKED OFFSHORE                   26 well integrity
                   A decrease of 3.1 million
                                                     233 other
                   from 2019

           0 FATALITIES

                           1 SERIOUS             7                         368
                            INJURY                                         DANGEROUS
                                                 ACCIDENTS
                                                                           OCCURRENCES

       27
       INJURIES                                                      60
       includes lost time ≥ 3 days,                                   WELL INTEGRITY
       alternative duties and medical                                 INCIDENTS
       treatment injuries

                                                     8
                     18 COMPLAINTS                   ENVIRONMENTAL
                                                     MANAGEMENT
                    Regarding duty holder
                                                     INCIDENTS
                    performance

20 THE REGULATOR ISSUE 2 2021
TOTAL FIXED
                                                                                                                                    FACILITIES
                                                                                                                              1
                             Facility                                                                                                  7         5
                                                                                                                          1
                             types
                                                                                                                      1
                                                                                                                                            21
                             Fixed facilities                                         6
                                                                              6
                                         Pipeline                                 TOTAL FIXED
                                                                                   FACILITIES
                                                                          7                         27
                                         FPSO
                                         Floating facility                            53
                                        Platform NNM
                                        Not normally manned
                                                                                  7
                                                                                                                                  NT
                                                                                                                                                                                     2020 OFFSHORE

                                         Platform NM
                                         Normally manned

                                         Subsea                                                                                                                QLD
                                         Infrastructure                                         5
                                                                                                                                                                                     INDUSTRY ACTIVITY

                                                                                                                 WA

                                                                                                    439
                                           Seismic                                                                                     SA
                                           activity
                                                                                                                                                          NSW

                                                                                                                                                                                           1
                                                                                                                                                                     ACT
                                           Wells
                                                                                                                                                         VIC                         12
                                                                                                                                                                                 7      TOTAL FIXED
                             Note: There was no greenhouse gas activity                                                                                                                  FACILITIES
                             in NOPSEMA’s jurisdiction in 2020.

                                                                                                                                                           TAS
                                                                                                                                                                                          75
                                                                                                                                                                           454                        55
                                                                                            7 Mobile offshore
                                                                                                drilling units                     1
                                                                                                                                       TOTAL FIXED
                                                                                                                                        FACILITIES
                                                                                                                                                     2
                                                                                                                                            4
                                                                                                                                   1                                 12

THE REGULATOR ISSUE 2 2021
                                                                                            6 Vessels

21
Expression
       of interest:
       Help us improve
       our website
       In June NOPSEMA successfully
       launched its new website.
       The new website has integrated
       NOPSEMA’s three pillars of
       Safety, Integrity and Environment
       into one ‘Offshore Industry’
       section.
       NOPSEMA is now looking to
       refine the user experience by
       seeking expressions of interest
       from interested stakeholders to
       provide their feedback on the new
       website. All feedback will be used
       to inform future improvements
       to the website including design,
       structure, and functionality.
       If you are interested in
       participating, please visit
       our website and complete the
       online form.

22 THE REGULATOR ISSUE 2 2021
Report an
incident

To notify NOPSEMA of
an accident, dangerous
occurrence, environmental
or well integrity incident call:
1300 674 472

                              THE REGULATOR ISSUE 2 2021   23
nopsema.gov.au

National Offshore Petroleum Safety and
Environmental Management Authority (NOPSEMA)
ABN 22 385 178 289
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