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Inspections – Other Areas Other Areas Interface documents between operators & contractors EMS – review previous EMS

DECC Presentation. Inspections. Inspections – Other Areas Other Areas Interface documents between operators & contractors EMS – review previous EMS audit report Heli -Fuel Skid – condition as often exposed ODS/F-Gas – new legislation Pigging Operations Are pigging areas bunded ?

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Inspections – Other Areas Other Areas Interface documents between operators & contractors EMS – review previous EMS

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  1. DECC Presentation Inspections Inspections – Other Areas • Other Areas • Interface documents between operators & contractors • EMS – review previous EMS audit report • Heli-Fuel Skid – condition as often exposed • ODS/F-Gas – new legislation • Pigging Operations • Are pigging areas bunded? • Are areas clean – any evidence of oil/wax outside bunded area? • Pipeline Integrity

  2. DECC Presentation Reporting Reporting • Self Reporting • PON 1 • Non-compliances – OPPC, OCR, PPC, F-Gas/ODS • Permitted Discharge Notification • PON 2 • Aerial Surveillance • Satellite Surveillance • Whistleblowers

  3. PON1 Report • Pollution Report • Requires: • Reporter Details • Installation / Location Details • Type of Spill – oil / chemical • Amount Spilled • Spill Ongoing – Y/N • Source of Pollution • Cause of Pollution • Steps being taken • Will it reach Median Line? • Weather Conditions • Electronic PON1 now in use

  4. DECC Presentation Reporting Examples • Diesel spill during bunkering • Paint spilled while changing tip of spray gun • Oil in Produced water > 100mg/L and bad sheen outwith 500m zone • Hydraulic actuation valve wears and releases more chemical than normal • 100L diesel spilt to deck and washed to recoverable drains system • Permitted to use 12T of chemical but used 13T Oil PON1 Chemical PON1 OPPC NC & PON1 PDN Chemical PON1 Neither – provided no sheen outwith 500m and recovery system working – then NC Not OCR NC

  5. DECC Presentation Aerial Surveillance

  6. DECC Presentation Aerial Surveillance

  7. DECC Presentation Satellite Surveillance

  8. DECC Presentation Satellite Surveillance Oil Sheen Hit: 11.4 x 0.15 km (1.6km2) – from sand wash discharges at night

  9. DECC Presentation Spill Statistics 2004 – 10

  10. DECC Presentation Spill Statistics 2004 - 09

  11. DECC Presentation Investigations • What do we Investigate • Size, scale and nature of spill • Environmental impact and potential impact • Location of incident, e.g. special area of conservation or other environmentally sensitive area • Permit holders / operators past performance • Seriousness of any potential breach of the law • Notification that may give rise to public concern or media interest • Potential for offshore investigation by DECC – Statement Taking

  12. DECC Presentation Enforcement • Enforcement action in line with DECC Enforcement Policy • Warning Letter • Enforcement Notice • Prohibition Notice • Prosecutions • Revoke Permit • Revoke Licence

  13. DECC Presentation Investigations • Common Factors and Learning • Routine Operations • Reinforce Risk Assessment procedures • Procedures ‘not followed’ or ‘not in place’ • Review competency and training • Ensure roles and responsibilities are understood • Communication failures • Maintain ownership of task • Equipment failure / lack of maintenance • Operator error • Lateral learning within / between companies • Post incident Implications

  14. DECC Presentation Investigations • Kittiwake – 4 April 2007 • Reported loss of 100bbls (19T) crude from parted hose between tanker and platform • Vessel lost position and hose ruptured • Potential to spill 94m3 (110T) from 3km pipeline • Surveillance aircraft mobilised – 2 hour ETA • SBV struggled to spray dispersant due to damaged hose • Caused by inexperienced officer of the watch failing to understand / respond to DPS instrumentation / alarms

  15. DECC Presentation Investigations Clair 22 March 2007 • Release of 4.3 tonnes OBM during bunkering operations • Failure of Straub coupling on hard piping between loading station and mud pits • Poor design selection • Couplings not recommended for hydrocarbon service • Seals not suitable for hydrocarbon service • BP selection criteria not followed

  16. DECC Presentation Investigations Beatrice Alpha 24 April 2008 & 3 June 2008 • 2 Spills of approx. 300 litres • Poor start up procedures • Lack of WEMCO level control • Passing valves • Crude formed tarry balls on sea surface • Washed up on coast within 1-2 weeks • Extensive clean up required by operator

  17. DECC Presentation Investigations Jade 27 October 2009 • Release of 6 tonnes diesel during bunkering operations • Faulty interlock valve stuck in open position • Poor procedures • Operating practices between Jade/Judy unclear • EC equipment not identified • Need to review operating practices & philosophies • Review Environmentally critical systems & provide additional training

  18. DECC Presentation Environmental Reps • What can Environmental Reps do • Site Audits – drains, hoses, ECE, weeps/seeps, bunds, etc • Involvement in Investigations • Reinforce Environmental / Regulatory message to offshore staff • Encourage Environmental aspect to Safety Observation Systems • Encourage cross learning intra-company • DECC inspection preparation • Meet with DECC inspectors

  19. THANK YOU

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