Validation

OPGGS Regulations

The Offshore Petroleum and Greenhouse Gas Storage (Safety) Regulations 2009 (OPGGS) set out the requirements for the contents of safety cases.

The OPGGS Regulations, state that NOPSEMA may, by notice in writing, require the operator of a proposed facility or an existing facility, to provide a validation in respect of the proposed facility or in respect of a proposed significant change to an existing facility.

A facility cannot be constructed, installed, operated, modified or decommissioned without a safety case in force for that stage in the life of the facility. The operator of a facility must submit the safety case for a facility to NOPSEMA. This submission should include a covering letter stating that the safety case is being submitted for assessment. Since it is the operator that must submit the safety case, registration of the operator must be completed (and a scope of validation for a proposed facility agreed) prior to safety case submission.

NOPSEMA internal processes

In order to deliver a consistent approach to validation of proposed facilities or to significant change to existing facilities, NOPSEMA has recently reviewed and reinforced its internal processes to ensure that an administrative process is in place that is accurately aligned with the requirements of the legislation. As a result, NOPSEMA has developed a Validation Policy (PL0286).

Once a validation is requested by NOPSEMA, an operator may not submit the safety case for a facility before the operator and NOPSEMA have agreed on the scope of validation for the proposed facility or proposed significant change to an existing facility.

Where validation has been requested, adequate validation forms part of the safety case acceptance criteria and therefore validation will need to be completed and received by NOPSEMA before the end of the assessment period in order for the Safety Authority to accept the safety case.

Click on the diagram below to enlarge.

Image - Safety case lifecycle

Timeframes

In general, the regulations impose safety case assessment time frames on NOPSEMA. For a NEW safety case, NOPSEMA has 90 days in which to either notify the operator that the safety case has been accepted, rejected, or to propose a new assessment timeframe. If the initially submitted safety case is not acceptable, NOPSEMA will either notify the operator that the safety case has been rejected or seek additional written information.

For REVISED safety case, NOPSEMA has 30 days to notify the operator.