IMCA Safety & Environment Seminar 2012 Rio de Janeiro, Brazil - PowerPoint PPT Presentation

IMCA Safety & Environment Seminar 2012 Rio de Janeiro, Brazil 21-22 March 2012 Design a facility rather than build a vessel Jane Cutler CEO NOPSEMA 22 March 2012

What we will cover • Context • Definition of facility • As Low As Reasonably Practicable (ALARP) • Performance-based vs. prescriptive • FPSO performance • Case Studies • NOPSEMA’s Role • Questions A206231 22 March 2012 2

Legislative Context Offshore Petroleum and Greenhouse Gas Storage Act 2006. Objectives : • To secure the health, safety and welfare of persons at or near facilities • To protect people at or near facilities from risks arising out of activities being conducted at facilities Key duty holder - operator of a ‘ facility ’ A206231 22 March 2012 3

Facility Definition Includes vessels: • Providing accommodation for persons working on another facility • Drilling or servicing a well for petroleum or associated work • Laying pipes or doing work on an existing pipe • Erecting, dismantling or decommissioning another facility A206231 22 March 2012 4

ALARP An operator of a facility must take all reasonably practicable steps to ensure that the facility, and its operations, are safe and without risk to the health of any person at or near the facility – reduce risk As Low As Reasonably Practicable (ALARP) A206231 22 March 2012 5

Safety Case Where a vessel or structure is a facility, there is a legal obligation on the operator of that facility to submit a safety case to NOPSEMA for acceptance prior to commencement of operations. A206231 22 March 2012 6

Performance-based vs. Prescriptive • Vessel rules, codes and standards – typically prescriptive – intended for marine vessels • Aspects of these prescriptive requirements may be used to make a part of the case for safety, • Compliance with prescriptive marine requirements may not meet ALARP requirements for a facility A206231 22 March 2012 7

% Incidents per Facility Type % Incidents - Platforms % Incidents - FPSOs / FSOs 50% 50% 40% 40% Over 40% 30% 30% of all 20% 20% incidents reported to 10% 10% NOPSEMA 0% 0% 2005 2006 2007 2008 2009 2010 2011 2012 YTD 2005 2006 2007 2008 2009 2010 2011 2012 YTD occur on % Incidents - MODUs % Incidents - Vessels FPSO/FSOs 50% 50% 40% 40% 30% 30% 20% 20% 10% 10% 0% 0% 2005 2006 2007 2008 2009 2010 2011 2012 YTD 2005 2006 2007 2008 2009 2010 2011 2012 YTD A206231 22 March 2012 8

Comparison – FPSOs and other facilities ALL Facility Types Number of Incidents Notified - 2011 FPSO/FSOs 120 80 40 0 Unplanned Damage to Could have Could have Accident - Other kind Uncontrolled Fire or Uncontrolled Accident - Collision Uncontrolled Pipelines - Event - safety-critical caused caused Death Incapacitation needing HC gas Explosion PL release Death or marine vessel HC gas kind needing Implement equipment Incapacity ( or Serious >=3 days LTI immediate release >1- >80-12 500L Serious Injury and facility release >300 immediate ERP LTI>3) Injury investigation 300 kg kg investigation A206231 22 March 2012 9

Hydrocarbon Releases HCR Rates All Facility Types All Facility Types vs FPSO/FSOs FPSO/FSOs 10 8 Rate per million hours 6 4 2 0 2005 2006 2007 2008 2009 2010 2011 A206231 22 March 2012 10

Damage to Safety Critical Equipment Damage to safety-critical equipment Rates All Facility Types All Facility Types vs FPSO/FSOs FPSO/FSOs 25 20 Rate per million hours WARNING 15 What is this telling 10 us? 5 0 2005 2006 2007 2008 2009 2010 2011 A206231 22 March 2012 11

Case Study 1: Lifeboats • Offshore construction vessel intending to conduct construction activities associated with an operating petroleum facility • Operator’s safety case says vessel is Special Purpose Ships (SPS) Code Compliant • The SPS Code (in Reg 8.2) allows compliance with SOLAS Ch III (Passenger Ships) A206231 22 March 2012 12

Totally Enclosed Motorised Survival Craft (TEMPSC) A206231 22 March 2012 13

Case Study 1 cont’d • SOLAS Ch III - lifeboats may be substituted (up to 37.5%) by life rafts • For vessels (facilities) which may be exposed to hydrocarbon risks – good industry practice - provide lifeboats for 100% POB capacity on each side of the facility (depending on major accident events) – Used by operators of vessels that are facilities – Generally considered a practicable option (ALARP principle) A206231 22 March 2012 14

Case Study 2: Gas detectors • Few IMO / SOLAS / Class requirements for gas detection • Vessels ( facilities) in hydrocarbon hazard environments require: – immediate indication of hydrocarbon releases – prompt emergency action • Some vessel operators choose to: – fit gas detection equipment – link it to ESD actions e.g. shut-off of dampers to engine intakes to prevent ignition A206231 22 March 2012 15

Case Study 2 cont’d Example of action taken Revised safety case - risks from hydrocarbon hazards: • Gas detection system fitted to vessel • 4 x TEMPSC = 200% POB (100% capacity + 100% redundancy) • POB weight monitoring system to avoid overloading the lifeboat davit A206231 22 March 2012 16

NOPSEMA’s Role A206231 22 March 2012 17

Case Study 3 - Dynamically Positioned Offshore Construction Vessel Activities proposed: • Diving; • Well intervention; and • Construction near petroleum production facility NOPSEMA Challenge: • How does the operator ensure the health and safety of persons on the vessel facility in the event of a loss of containment of hydrocarbon on the adjacent petroleum production facility? A206231 22 March 2012 18

Case Study 3 cont’d Some of the responses received from operators: • “The vessel is not built to that standard. As the vessel is not a hydrocarbon producing facility it does not need ESD and Gas detection” • “The other facility will tell us there is a gas release” • (In relation to lifeboats ‘TEMPSC’) “The Special Purpose Ships Code does not require enclosed lifeboats… we have life-rafts” • “We would always be able to move off” • “You would be able to see a gas vapour cloud” • “If you were in a gas cloud, what would be the point of a gas detection system anyway (at that stage)?” • “Class don’t require any of these measures, the vessel meets their standards” A206231 22 March 2012 19

PTTEP August 21 - Montara Blowout & Escape Montara 21 August 2009 A182696 20 20

What can happen? • Hydrocarbon vapour cloud ingested into diesel engine turbo charger intakes and ignited (Macondo) A206231 22 March 2012 21

Jascon 25 salvage vessel alongside Montara / West Atlas Wreck

Relevant Standards • Vessels undertaking well intervention or similar work – standards available which describe options for vessel design which contribute to mitigation of hydrocarbon risks • These standards address matters such as: – Location of Air intakes – ESD shut down principles – Hazardous Area Classification – Considerations for combustion engines (eg Ignition, Over-speed) – Rating of electrical equipment in hazardous Areas • e.g. DNV-OS-A101 A206231 22 March 2012 23

FPSO Case Study • Incident: Fire and explosion • Issues: – Facility Design – Commissioning, QA/QC, carry-over into operations – Competency and training – Control room alarm flooding – Maintenance management A206231 22 March 2012 24

FPSO Case Study • Regulatory intervention: Inspections • Major deficiencies identified in: – Maintenance backlog management – Effectiveness of operational control – SCEs not meeting performance standards – Reportable incidents – Housekeeping • Enforcement action included: – Improvement Notices – Prohibition Notice A206231 22 March 2012 25

FPSO Case Study • Initial response to intervention: – Delegation to contractor – Completion dates not fully met – Over reliance on NOPSEMA to identify health and safety issues • Intervention options: – Inspections – Potential escalation of enforcement • notice of intent to withdraw safety case • request revised safety case A206231 22 March 2012 26

Conclusions It should not be assumed that the risk control measures that may be considered suitable for a vessel will necessarily meet the ALARP requirements for a facility A206231 22 March 2012 27

Any Questions? www.nopsema.gov.au 28