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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.
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Early Engagement Jeremy Dunster Manager Technical Services APPEA - - PowerPoint PPT Presentation
Early Engagement Jeremy Dunster Manager Technical Services APPEA - - PowerPoint PPT Presentation
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
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The Operator’s General Duty
The operator of a facility must take all reasonably practicable steps to ensure
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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
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Where we are now
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Stages in the life of a facility
Context: Legislative framework (Safety)
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Exploration & Appraisal Concept Evaluation Conceptual Design FEED Detailed Design Overseas Construction Field Construct & Install Operate (Production) Modify
Decommission
P(SL)A Schedule P(SL)A MoSoF Regulations OPS Regulations OPGGS(S) Regulations
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Context: The Rise of Gas
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Early Engagement Today: Provisions
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Exploration & Appraisal Concept Evaluation Conceptual Design FEED Detailed Design Overseas Construction Field Construct & Install Production Modify
Decommission
SoV Flexibility Fee for assessment of a safety case for a proposed Facility Submission for Assessment, Scope, Feedback
SC
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Safety Management System Description Formal Safety Assessment Description Monitor, Audit and Review Facility Description
Description of Technical Controls including:
Emergencies Activities and O perating Parameters G eneral Description
(the layout of the facility)
Machinery and Equipment Safety Measures HAZID Risk Assessment Emergencies (EERA, FERA) Performance Standards
Description of Procedural Controls including:
Identification of Control Measures Implementation and Improvement of the SMS Scope (Activities) O HS Risk Management Maintenance Communication Emergencies Safety Measures
C
- rrective &
Preventative action Implemented & F unctional? Implemented & F unctional?
Comprehensive and Integrated
Monitor, Audit and Review
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SC SC FID Concept Selected
Early Engagement Safety Case Assessments to-date
Early Engagement Today: Participants
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Concept Evaluation Conceptual Design FEED Detailed Design Overseas Construction Field Construct & Install Production
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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
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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.
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Drivers for change
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Reasonable Practicability
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Cost to avert Risk
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Bounded Practicability: The Risk Playing Field(s)
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High Risk Low Risk Concept Design Construct, Install, Operate, Modify, Decommission
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Reasonable Practicability: Passage of time
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Concept Evaluation Conceptual Design FEED Detailed Design Overseas Construction Field Construct & Install Production Starts
Concept Selected FID SC SC
Time
Cost to change Reasonable
- pportunity to
challenge
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Where we are headed
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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
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Conclusion
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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.
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Our Vision
A safe and environmentally responsible Australian offshore petroleum industry.
Our Mission
To independently and professionally regulate offshore safety, integrity and environmental management.