uk –environmental emergency response arrangements … · 19 euaog emergency response workshop 30...

OFFICIAL

UK – ENVIRONMENTAL EMERGENCY RESPONSE ARRANGEMENTS

EUOAG WORKSHOP30 June 2016

Nicholas Woollacott

Offshore Environmental Inspector

Department of Energy & Climate Change

Agenda

• Summary of the UK regime to respond to environmental

incidents from offshore oil and gas operations;

• Implementation of the OSD requirement to demonstrate

oil spill response effectiveness as part of the IERP;

• Implementation of the OSD requirement to specify an

inventory of available oil spill response equipment as part

of the IERP; and

• Environmental IERP requirements for Non-Production

Installations and links to the UK safety case regime.

2 EUAOG Emergency Response Workshop 30 June 2016

Environmental Emergency Response

• DECC – UK Regulator for the environmental aspects of

Offshore Oil and Gas Industry. Part of the new Competent

Authority – Offshore Safety Directive Regulator (OSDR)

• The International Convention on Oil Pollution

Preparedness, Response and Co-operation 1990

implemented by domestic regulation for offshore oil and

gas installations and pipelines

• Operators (and NPI owners) required to hold an approved

Oil Pollution Emergency Plan (OPEP) for any operation

that presents a risk of oil pollution



• All OPEPs must be compatible with the UK National

Contingency Plan which provides the Strategic Overview

for Responses to Marine Pollution from Shipping and

Offshore Installations.

• The ‘Responsible Person’ for OPEP submissions and

subsequent implementation:

o Installation Operator;

o Well Operator; or

o Owner of a Non-Production Installation



• The Responsible Person is required by regulation and

permit conditions to report any release or unpermitted

discharge of oil or offshore chemicals to DECC

• Web based oil & gas portal hosts the PON1 reporting tool.

o All releases or unpermitted discharges must be

reported within 6hrs of the incident.

o A release of 1 tonne or more (oil or offshore chemicals)

must be reported to DECC on call inspector within 1hr.

• Applicable incidents must also be reported in accordance with

the Implementing Regulation – 60Kg liquid petroleum



8 EUOAG Emergency Response Workshop 30 June 2016


• In the event of any oil release the Responsible Person is

required to implement the OPEP.

• DECC specify 34 areas of OPEP content which include:

• Response Initiation / Direction

• Contractor Mobilisation

• Oil Characteristics

• Training & Exercises

• Worst Case Release

• Modelling

• Cap / Relief Well Mobilisation11 EUAOG Emergency Response Workshop 30 June 2016


• DECC provide a 24/7 on call Offshore Environmental

Inspector to respond to any offshore environmental

incidents/urgent permit requests

• DECC have regulatory powers to monitor the Responsible

Persons response to an environmental incident

• DECC utilise an ‘Incident Response Manual’ to detail roles

undertaken, media liaison, ministerial notification etc

• Separate UK legislation creates the role of the Secretary of

States Representative (SOSREP) and provides intervention

powers in the event of potential significant pollution 12 EUAOG Emergency Response Workshop 30 June 2016

Oil Spill Response Effectiveness

• The OSD required IERP is delivered in the UK by updates

to The offshore installations (prevention of fire and

explosion, emergency response) regulations (PFEER) and

the Merchant Shipping (Oil Pollution Preparedness,

Response and Co-operation Convention) regulation

(OPRC)

• One of the new requirements delivered by the amended

OPEP regulations was the inclusion of ‘an estimate of oil

spill response effectiveness’ including consideration of the

environmental conditions as specified in OSD



• To deliver this requirement for all offshore Oil and Gas

operations Oil & Gas UK contracted Oil Spill Response

Limited to produce guidelines “Oil Spill Response

Effectiveness in UK Waters”

• The guidelines are intended to be used as either an Annex

to the the OPEP or be linked to from the OPEP to provide

the required oil spill effectiveness demonstration.

• The guidelines detail response effectiveness based on

regional weather data and oil type for seven common

response systems.



• Metocean data specific to operating location and

information regarding ITOPF oil type is used by Operators

to extract the particular oil spill response effectiveness

from the guidance document.




Seven oil spill response systems that were identified in

consultation with OGUK Members and DECC:

1. Aerial Dispersant

2. In-situ Burn

3. Monitor & Evaluate

4. Natural Dispersion

5. Contain and Recover

6. Shoreline Cleanup

7. Vessel Dispersant

Oil Spill Response Effectiveness – B1


Aerial Dispersant Contain and Recover

Natural Dispersion

Wind Speed Between 6 kts & 27 kts Less than 20 kts All wind speeds

Visibility More than 3 nm More than 1 nm Does not affect response

Precipitation Does not affect response Does not affect response Does not affect response

Temperature Does not affect response Does not affect response Does not affect response

Tidal State Does not affect response Does not affect response Does not affect response

Current Speed Does not affect response Does not affect response Does not affect response

Ice & Debris N/A in UK Climate N/A in UK Climate N/A in UK Climate

Daylight Dawn to 30 mins before Dusk

Dawn to 30 mins before Dusk

Does not affect response

Wave Height Between 0 m & 4 m Between 0 m and 2.5 m All wave heights



Environmental Data

The environmental (metocean) data provider for the

project was BMT ARGOSS Ltd.

The various metocean data sources are referenced in

the document with the exact locations of grid points

for all parameters.

The operational limitations of the response techniques

and further information on data calculation methods

utilised are detailed in the document.

Inventory of available response equipment


Second new requirement of the IERP that was

implemented through the amended regulatory regime

• Each OPEP must fully describe the inventory of

available oil spill response equipment available

• The OPEP should reference the register of

equipment held by any contracted oil spill response

provider – Capability statement

• Supplemented by any additional equipment held

not in the register - Installation/field specific

Inventory of available response equipment


• For any equipment not detailed in the response

providers capability statement the owner/operator

must confirm the following in the OPEP:

i. Details of ownership;

ii. Storage locations;

iii. Transport arrangements to deployment site;

iv. Mode of deployment; and

v. Measures in place to ensure equipment and

procedures are maintained in an operable

condition.

Non Production Installations


Another key consequence of the amended OPEP

regime is that Non-production installations (NPI) must

hold their own approved OPEP.

• Previously all oil spill response arrangements for

combined/well operations utilising a NPI were

included as addendums to the licenced operators

installation OPEP

• In the new regime each NPI has its own OPEP which

is described in the Safety Case



• The NPI OPEP can be prepared in accordance with a

template developed by IADC in consultation with

DECC

• The NPI OPEP details the non-location specific

aspects of the oil spill response arrangements

(Incident reporting, training, exercises,

arrangements for interface with Well/Installation

Operator etc)



• Updated by the Well/Installation Operator through

a Communications & Interface Plan (CIP) or

Temporary Operations OPEP.

• Reduced review timescale for Combined Operations

OPEP submissions (21 days vs 2 months).

• Potential to use an updated specific section in

existing interface documents to deliver the CIP.



• Schedule of OPEP updates to coincide with

transition of all Safety Cases to the 2015 Safety Case

Regulations.

• Fully updated DECC OPEP guidance published in

January 2015, updated May 2015 & August 2015

following industry engagement.

Further Information


The Offshore Safety Directive Regulator website can be

found at:

http://www.hse.gov.uk/osdr/

Information provided includes OPEP Guidance and

assessment templates.

uk –environmental emergency response arrangements … · 19 euaog emergency response workshop 30...

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