Early Engagement Jeremy Dunster – Manager Technical Services APPEA Conference Adelaide, 14 May 2012
The Objective Facilities that are safe and without risk to the health of any person at or near them. 14 May 2012 A207354 2
The Operator’s General Duty The operator of a facility must take all reasonably practicable steps to ensure that the facility is safe and without risk to the health of any person at or near the facility * * Subclause 9(1)(a) of Schedule 3 to the Offshore Petroleum and Greenhouse Gas Storage Act 2006 14 May 2012 A207354 3
Where we are now
Context: Legislative framework (Safety) Exploration & Appraisal Concept Evaluation Conceptual Design P(SL)A Schedule FEED P(SL)A MoSoF Regulations OPS Regulations Detailed Design OPGGS(S) Regulations Overseas Construction Field Construct & Install Decommission Operate (Production) Modify Stages in the life of a facility 14 May 2012 A207354 5
Context: The Rise of Gas 14 May 2012 A207354 6
Early Engagement Today: Provisions Exploration & Appraisal Concept Evaluation Conceptual Design FEED SoV Flexibility Detailed SC Design Overseas Construction Fee for assessment of a safety Field Construct case for a proposed Facility & Install Decommission Production Submission for Assessment, Scope, Feedback Modify 14 May 2012 A207354 7
Facility Formal Safety Safety Management Description Assessment Description System Description Activities and HAZID Scope (Activities) O perating Parameters G eneral Description Comprehensive (the layout of the facility) and Integrated Machinery and Equipment Description of Procedural Controls including: Description of O HS Risk Management Technical Controls Risk Assessment including: Maintenance Safety Measures Communication Emergencies (EERA, FERA) Emergencies Safety Measures Emergencies Identification of Performance Standards Control Measures C orrective & Implemented Monitor, Audit and Review Monitor, Audit and Review Preventative action & F unctional? Implementation and Improvement of the SMS Implemented & F unctional? 14 May 2012 A207354 8
Early Engagement Today: Participants Concept Selected Concept Evaluation Conceptual FID Design FEED Detailed SC Design Overseas SC Construction Early Engagement Safety Field Construct & Install Case Assessments to-date Production 14 May 2012 A207354 9
Early Engagement Today: Experiences • Positive feedback regarding process • Useful introduction for new operators • A limited opportunity to question: – Safety & design philosophies – Concept selection – Design choices – ALARP demonstration 14 May 2012 A207354 10
Early Engagement Today: Challenges • No provisions for Concept selection & Design • Dialog constraints (requests for further information) • Decision making focus of the regulations • Optional process, no submission trigger = Sub-optimal arrangements with limited potential to improve safety outcomes. 14 May 2012 A207354 11
Drivers for change
Reasonable Practicability Risk Cost to avert 14 May 2012 A207354 13
Bounded Practicability: The Risk Playing Field(s) High Risk Construct, Install, Operate, Modify, Decommission Concept Design Low Risk 14 May 2012 A207354 14
Reasonable Practicability: Passage of time Concept Selected Concept Evaluation Conceptual FID Design FEED Detailed SC Design Overseas SC Construction Reasonable Field Construct opportunity to & Install Cost to change challenge Production Starts Time 14 May 2012 A207354 15
Where we are headed
Future Directions: work in progress • Research & evaluation of options • Design notification: – Focus on concept selection & design – Required for production facilities – Submitted no later than a Field Development Plan – Basis for ongoing dialog transitioning into submission of a safety case 14 May 2012 A207354 17
Conclusion Effective provisions for early engagement: increasing the likelihood that future production facilities are safer and with lower risk to the health of any person at or near them. 14 May 2012 A207354 18
Our Vision A safe and environmentally responsible Australian offshore petroleum industry. Our Mission To independently and professionally regulate offshore safety, integrity and environmental management.
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