Off the shelf monitoring programs
Article published in the Regulator | Issue 5: 2012
The Montara Commission of Inquiry found major deficiencies with respect to the environmental monitoring that was conducted in the wake of the PTTEP AA Montara blowout in 2009 and made recommendations to address those deficiencies. One of the recommendations included putting in place operational and scientific monitoring programs (OSMPs) that could be rapidly implemented in the event of a hydrocarbon spill, specifically in order to address deficiencies around the lack of baseline data and delayed implementation of the environmental monitoring program for the Montara accident.
The Commonwealth Government response to this recommendation identified NOPSEMA to lead the implementation of OSMPs, which is to be achieved through the Environment Regulations and be supported by regulatory advice on how operators may prepare a fit-for-purpose OSMP as part of the environment plan process, including:
updates to the environment plan preparation guidance note
detailed information for consideration when developing OSMPs.
This will provide useful information to operators on overarching principles and possible approaches to a monitoring program’s design and implementation that will assist operators to meet their oil spill monitoring related legislative requirements. For example, compliance with OPGGS Environment Regulations and also the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) approval conditions could be met with a single monitoring document. NOPSEMA is consulting with the Department of Sustainability Environment, Water, Population and Communities (SEWPaC) with the aim of minimising the regulatory burden on operators and government alike.
As with other NOPSEMA advice, the OSMP information will be non-prescriptive to afford operators flexibility in application of monitoring scope and method appropriate to nature and scale. This also encourages consideration of latest innovations and continual improvement in monitoring programs to reflect any advances in technology, sampling methodologies and knowledge. It will also cover advice on assessment of the environment’s response to, and recovery from, the impacts of an unplanned marine oil spill. Operators will then develop and be ready to implement, fit-for-purpose and up to date OSMPs which are relevant to the environmental sensitivities and values of individual locations. These OSMPs would be assessed, along with other monitoring, as part of an environment plan for a petroleum activity.