Harmonisation of Oil Spill Prevention and Response in the Barents Sea: Reality or Just a Pipe Dream?
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Harmonisation of Oil Spill
Prevention and Response in
the Barents Sea:
Reality or Just a Pipe Dream?
Dr Tina Hunter
Director, Centre for International Minerals and Energy Law, University of Queensland
TC Beirne School of Law: First in Law
Presentation Outline
• Legal regimes for petroleum
activities
• International Law
• ‘Soft Law’
• National law
• Oil spill prevention and
response
• Regulatory Bow Tie
• Conclusion: prevention vs
response
TC Beirne School of Law: First in Law
Barents Sea Petroleum Reserves Source: Ole Gunnar Austvik, Oil and Gas in the High North: A Perspective from Norway
Legal Regimes – International Law • No ‘international law’ for petroleum activities • IADC, API, ISO, NORSOK • UNCLOS – particularly a56 (EEZ), a76 (CS), a234 • IMO – eg SOLAS • Agreement on Cooperation on Aeronautical and Maritime Search and Rescue in the Arctic • Illulissat Declaration (Ship Based) • Other ship based international oil conventions
Regional agreements • Regional law – OSPAR • Signatories • Copenhagen Agreement • Bonn Agreement • European Maritime Safety Agency • Norway-Russia Cooperation • Arctic Cooperation through Arctic Council
Legal Regimes – Soft Law
• Northern Dimension policy
• Arctic Council
March 20, 2014 AOOGG: Systems Safety Management and Safety
Culture
• PAME Working Group
• Arctic Offshore Oil and
Gas Guidelines 2009
• AOOGG: System Safety
Management and Safety
Culture
• SHOULD THERE BE
BINDING INSTRUMENTS
FROM AC? or DOES SELF i
REGULATION WORK?
Legal Regimes: just about compliance?
• Objective-based regulation vs prescriptive regulation
• Never forget the early lessons – Alexander Kielland; Piper Alpha
• But: ‘Piper Alpha’ process safety superseded by the Macondo/
Montara ‘well integrity’
• Safety Culture
• Standards and Best Practice
• ALARP/Safety Case vs GOP
• Risk Assessment and Hazard Identification
• Inspection not just approval of WOMPS
• Comparison to building industry
• Norway
• Risk-based – Identify risk; utilise barriers
• Russia
• More prescriptive?
• Use of Risk based assessment of HSE?PREVENTION RESPONSE
Emergency
Response -
Well Evacuation, etc
design/
construction Monitoring
CBL
Well Control
THREAT: EVENT Response Plan
Well Integrity
Cement Well BOP Hydrocarbon
Job integrity
test Spill Response
Plan
Barriers
Adapted ‘Bow Tie’ analysis of prevention of, and response to, loss of well integrity in conventional
petroleum operationsBarrier management in Norway
Barrierer management process –ISO 31000
Context
System definition, -description and assumptions
Regulations, standards, best practices , company specific requirements a.o.
Risk assessment
Hazard Identification
(per area and for all relevant potential internal/external hazards and accidents
Etablish barrier functions, -elements and performance requirements
Communicate and consult
(per area and for all relevant potential internal/external hazards and accidents
Monitoring and review
Perform risk analysis and safety related studies/analysis
(What can happen, how likely, what is the consequence ? Asses and compare with design-/acceptance criteria)
Asses and evaluate risk (Risk evaluation), incl. sensitivities , uncertainties
Establish the risk picture
Risk Treatment
Need for additional/ more effective barriers/risk reducing measures ?
YES
NO
Establish specific startegy and specific performance requirements
Document process /results from Specify perfomance
Risk evaluation and Risk requirements into
Treatment into
Performance standards
Strategy
Function/integrity/vulnerability
Specific per barrier/event/area
O. Thomassen, PSA PTIL/PSABarrier management in Norway
Barrierer Management Technical
barrier elements
•Containment
Context •Firedetection
System definition, -description and assumptions
Regulations, standards, best practices , company •Ventilaton/HVAC
specific requirements a.o •Gasdetection
•ESD
Risk assessment •Igntion Source control
Hazard Identification •Drainage Organisational
(per area and for potential internal/external
•Flare and relief barrierelements
hazards and accidents) •Passive fire protection •Competence
•Active firefighting •Communication/
Etablish barrier functions, -elements •Emergency power •Work practice
Communicate and consult
and performance requirements • etc…. Technical •Procedures
Monitoring and review
(per area and for all relevant hazards and •Work environment
accidents
•Man / machine
•Control,check,verify
Perform risk analysis and safety related •Documentation
studies Operational •Resources, Capacity
barrierelements •Work load / Time
Organisational
•Planning
Asses and evaluate risk Operational
•Design and arrgt. •Roles and responsebility
(Risk evaluation)
•Maintenance
Establish risk picture
•Operations and activities
•Modifications
Risk Treatment •Changes/ MOC
•Deviation handling
Need for additional/ more effective
barriers/risk reducing measures ?
•Work processes
YES
NO
Establish specific barrier strategy and
specific performance requirements
Plant specific barrier Performance requirements
Strategy (per area) Performance standards
O. Thomassen, PSA PTIL/PSALEVEL 1
ISO 31000
Regulatory Bow Tie
Risk management
-main principles Guideline on principles and implementation of risk management
(functional)
LEVEL 2
Safety barriers ISO 13702
and arctic offshore ISO 19906 Well integrity Risk assessment
ISO 10418
design Arctic offshore ISO proposal ISO 17776
Mitigations of fires structures NORSOK D-010
-main principles and explosions
LEVEL 3
Technical safety Well integrity Risk assessment
Safety barriers
NORSOK S-001 NORSOK D-010 NORSOK Z-013
LEVEL 4
Functional safety of E/E/PES
Drilling facilities
IEC 61508
NORSOK D-001
Instrumented safety system
IEC 61511
Production
Ventilation
Riser, X-mas tree,
Safety ISO 15138
SSCV
barrier
elements
Ignition source control
IEC 60079
IEC 61892 DWCO
Riser, BOP, Mud
IEC 80079Barents 2020
purpose of this project is to recommend HSE The seven selected topics from phase 2 which are
dards for common Norwegian - Russian addressed in this report are:
ication in the Barents Sea, for safeguarding
• Baseline Offshore HSE
ple, environment and asset values in
1
Recommend the basic list of internationally recognized
nection with oil and gas activities, including standards for use in the Barents Sea
Standards
transportation of oil and gas. The underlying
Recommend standards for design of stationary offshore
mption is that 2
• petroleum
Use of NS operations
system in theas units against ice loads in the Barents Sea
ents Sea shall be at least as safe as those in the
th Sea. baseline Recommend standards for Risk Management of major
Hazards, such as Fires, Explosions and Blow-outs on
3
Phase 1 of the• project
Norsklasted
PSA from October offshore drilling, production and storage units in the
Barents Sea.
7 to October 2008. The results of phase 1 were
• Harmonisation of Laws
umented in 5 “Position Papers”. The position
4
Recommend standards for evacuation and rescue
of people from ships and offshore units, including
ers provided the basis for further work in phase standards for rescue equipment
• Use of
sting from November 2008NSto system
March 2009, as
lting in the special topics prioritised for further Recommend standards for working environment and
baseline safety related to human performance and decision
y in expert working groups in phase 3. 5 making (Human factors) for operations in the Barents
The selection BUT
of topics for further work was Sea
ied out in close cooperation between the
• Regulation must be
wegian and Russian participating organisations. 6
Recommend safe standards for loading, unloading
and ship transportation of oil in the Barents Sea – to
minimize risk of accidental oil spills
contextual – best
process was constructive and quick, based on
h Russian and Norwegian proposals. There was Recommend standards for operational emissions and
7
practice is not abstract
agreement between the parties that the selected discharges to air and water in the Barents Sea
cs are among the most important issues which
but situational
d to be addressed in relation to safeguarding oil This report provides the findings and
gas operations in the Barents Sea. Still, some recommendations from these seven expert groups.
posed topics were left out, not because they are Group 1, also called RN01 (Russian –
mportant, but because they are addressed by Norwegian expert group number 1) summarizesBut…
What if there is a loss of well control ?Oil Spill response
• Response as close to
operation as possible Norwegian Equipment Depots
Svalbard
• Booming and Skimming NORWEGIAN COASTAL ADMINISTRATION
• Norwegian response NCA DEPOTS Tromsø
• Government, Private and
municipal contingency NOFO DEPOTS
(Norwegian Clean Seas Organisation)
system MAJOR PRIVATE DEPOTS
Trondheim
• All available resources in
Norway
society used to combat Bergen
Oslo
major spills
Stavanger
• Satellite monitoring Department for Emergency Response
• Graded contingency plans
• National, regional, local
• extended to Russian
areas ?Responding to Oil Spills
not just oil spill response
• Emergency Response
• Control and Mitigation of fires and explosions on offshore
production installations ISO 13702; NORSOK S-001
• Adapted for Barents sea
• Need for containment of HC
• Rescue and treatment of injured
• Ad
• Well control response
• Mobilisation of resources
• Human, technical,
• Capping stack – Wild Well Control
• Closest – AberdeenConclusions • Prevention is better than response - WELL INTEGRITY CRITICAL • Norwegian System provides excellence in safety (HSE) and spill response • Legal Framework predicated on objective-based regulation • Need to be cognizant of Bow Tie – • Barriers • Responses • Barents 2020 provides framework for prevention and response but.. • NEED FOR HARD LAW and EXPERTISE • Greatest challenge well control response?
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