Continual improvement in oil spill response
A central tenet of outcomes-based regulation is that of continual improvement. What this means is that the industry must regularly examine controls and arrangements to identify and implement possible improvements, such as adopting new technology, services, procedures, and practices, to meet increasing community expectations.
Following the Montara and Macondo disasters, the global oil and gas industry demonstrated its capacity for continual improvement by implementing a suite of joint industry projects to improve oil spill response capability. These projects brought substantial developments across globally pre-positioned capping stacks and ancillary equipment, dispersant stockpiles, and a range of other capability and preparedness measures.
To ensure the Australian industry maintained its focus on continual improvement, NOPSEMA established oil pollution emergency preparedness as one of its strategic compliance focus areas. We examined options for improvement in oil spill preparedness and capability and worked with the industry to implement the improvements. In 2017, NOPSEMA established the Spill Risk Cooperative Forum (SRCF) to provide
titleholders a forum where they could explore cooperative solutions for improved preparedness and response measures, solutions that would otherwise be out of reach for a single titleholder.
The success of the SRCF contributed to APPEA forming an industry Oil Spill Preparedness & Response Working Group (OSPRWG) to further develop and implement improvement options. NOPSEMA recently engaged with the OSPRWG while undertaking a revision of its Oil Pollution Risk Management guidance note. The revision was undertaken to incorporate industry feedback and improve the clarity and effectiveness of the guidance. The guidance note is now available for comment on our website and NOPSEMA encourages all of its stakeholders to provide feedback.
Internationally, NOPSEMA took a leading role as a member of the International Offshore Petroleum Environment Regulators (IOPER) group in establishing their Oil Spill Working Group. From 2018–20, NOPSEMA’s Drilling and Spill Risk Manager, Rhys Jones, chaired the group and led a work stream focussed on the timelines of source control response. Mr Jones reflected on the group’s work in leading improvement in oil spill response at the plenary session of the recent International Oil Spill Conference.
“Across the industry, it was clear to us that response planning was inconsistent and the logistics capability to deploy wasn’t uniformly understood. We saw an opportunity to improve
the timeframe for deploying a capping stack and source control equipment to respond to loss of well control,” said Mr Jones.
With that goal, NOPSEMA and IOPER partnered with APPEA in 2019 to host a Source Control Workshop. The workshop was attended by 120 participants from nearly 40 organisations who shared valuable knowledge on the tasks required to deploy and install a capping stack and where efforts should be directed to improve timeliness and effectiveness.
The learnings from the workshop led NOPSEMA and IOPER to collaborate with the International Association of Oil & Gas Producers (IOGP) to develop the Response Time Model (RTM). The RTM is a tool designed to assist titleholders in identifying the tasks and predicting the timelines for capping a well blowout. The IOGP published Report 592; a toolkit for the RTM to guide planning of timely source control emergency response. The report was co-presented by NOPSEMA and IOGP at the recent International Oil Spill Conference to disseminate the knowledge and the RTM to the global industry.
Through 2020–21, NOPSEMA and the APPEA Drilling Industry Steering Committee (DISC) worked to embed the learnings of the RTM into the Australian offshore petroleum industry. Recently, NOPSEMA and IOGP presented the work at the APPEA conference and announced the release of the APPEA Australian Offshore Titleholders Source Control guideline and the NOPSEMA Source Control Planning and Procedures information paper. The paper clarifies NOPSEMA’s expectations for source control content within an environment plan, well operations management plan, and safety case, as well as a source control emergency response plans (SCERP), which is an operational response plan developed and maintained by titleholders. APPEA’s guideline provides the industry with further details of the SCERP content requirements, consistent with IOGP guidance for source control.
Moving forward, NOPSEMA sees many more opportunities for continual improvement. This includes testing of global oil spill response capability to ensure it is operationally ready and improving arrangements for effective and efficient incident management control of a large-scale oil spill response. NOPSEMA will continue to focus on oil pollution emergency preparedness and work with the industry, technical authorities, and international regulatory counterparts to drive improvement.