Monitoring of impacts to the environment from oil pollution
Article published in the Regulator | Issue 6: 2014
In line with the government’s response to the Montara Commission of Inquiry recommendation to establish ‘off the shelf’ monitoring plans, NOPSEMA has targeted arrangements for the monitoring of impacts to the environment from oil pollution and response activities within an environment plan (EP).
Pre-determined post-spill monitoring arrangements are the principle tool for enabling identification of the extent, severity and persistence of environmental impacts from an oil spill, and are necessary to focus remediation efforts. Amended environmental regulations which commenced on 28 February 2014 clarified the content requirements of EPs for post spill monitoring.
Recently, NOPSEMA has identified that some titleholders are submitting EPs that contain post spill monitoring arrangements in which components for monitoring impacts to particular receptors (for example water quality, sediments, coral reefs, mangroves, seagrasses and fish) are excluded based on a risk assessment at the planning stage.
Predictions and risk assessment may provide good information with which to prioritise monitoring arrangements, however, titleholders should take care not to interpret these so rigidly as to inappropriately exclude certain arrangements. This is particularly important when uncertainty, such as oil type and characteristics or likelihood of contact with sensitive receptors, exists.
Well-developed post-spill monitoring arrangements can be made suitably flexible by including a suite of monitoring programs, each measuring a specific receptor, that are activated on an ‘as needs’ basis in the event of a spill. These monitoring arrangements can accommodate a range of spill outcomes because they have been designed to cover a variety of receptor types that may be affected by different spill risks.
Individual monitoring programs which include rational and logical activation arrangements mean that, in the event of a spill, only the modules that need to be implemented are activated. For example, the results of water quality information gathered during the operational response phase in an area over seagrass meadows may be used to activate monitoring of seagrasses.
To ensure appropriate monitoring arrangements are in place, titleholders should have access and commitments to implement monitoring of impacts to the environment from oil pollution and response activities. Provisions for an entire range of monitoring will ensure that the appropriate components are activated and that titleholders will be able to meet the requirements of the Environment Regulations.