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 2 22 March 2012

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’

3 22 March 2012 A206231

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

22 March 2012 A206231 4

ALARP An operator of a facility must take all reasonably practicable steps to ensure that the facility, and its

• perations, are safe and without risk to the health of

any person at or near the facility – reduce risk As Low As Reasonably Practicable (ALARP)

22 March 2012 A206231 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.

22 March 2012 A206231 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

7 22 March 2012 A206231

0% 10% 20% 30% 40% 50%

2005 2006 2007 2008 2009 2010 2011 2012 YTD

% Incidents - Platforms

0% 10% 20% 30% 40% 50%

2005 2006 2007 2008 2009 2010 2011 2012 YTD

% Incidents - FPSOs / FSOs

0% 10% 20% 30% 40% 50%

2005 2006 2007 2008 2009 2010 2011 2012 YTD

% Incidents - MODUs

0% 10% 20% 30% 40% 50%

2005 2006 2007 2008 2009 2010 2011 2012 YTD

% Incidents - Vessels

% Incidents per Facility Type

Over 40%

• f all

incidents reported to NOPSEMA

• ccur on

FPSO/FSOs

8 A206231 22 March 2012

Comparison – FPSOs and other facilities

9 A206231 22 March 2012

40 80 120

Unplanned Event - Implement ERP Damage to safety-critical equipment Could have caused Incapacity ( LTI>3) Could have caused Death

• r Serious

Injury Accident - Incapacitation >=3 days LTI Other kind needing immediate investigation Uncontrolled HC gas release >1- 300 kg Fire or Explosion Uncontrolled PL release >80-12 500L Accident - Death or Serious Injury Collision marine vessel and facility Uncontrolled HC gas release >300 kg Pipelines - kind needing immediate investigation

Number of Incidents Notified - 2011

ALL Facility Types FPSO/FSOs

Hydrocarbon Releases

10 A206231 22 March 2012

2 4 6 8 10 2005 2006 2007 2008 2009 2010 2011

Rate per million hours

HCR Rates

All Facility Types vs FPSO/FSOs

All Facility Types FPSO/FSOs

Damage to Safety Critical Equipment

WARNING What is this telling us?

11 A206231 22 March 2012

5 10 15 20 25 2005 2006 2007 2008 2009 2010 2011

Rate per million hours

Damage to safety-critical equipment Rates

All Facility Types vs FPSO/FSOs

All Facility Types FPSO/FSOs

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)

12 22 March 2012 A206231

Totally Enclosed Motorised Survival Craft (TEMPSC)

13 A206231 22 March 2012

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)

14 22 March 2012 A206231

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

22 March 2012 A206231 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

22 March 2012 A206231 16

NOPSEMA’s Role

17 A206231 22 March 2012

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
• f persons on the vessel facility in the event of a loss
• f containment of hydrocarbon on the adjacent

petroleum production facility?

22 March 2012 A206231 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”

22 March 2012 A206231 19

A182696 20

August 21 - Montara Blowout & Escape

20

PTTEP Montara 21 August 2009

What can happen?

• Hydrocarbon vapour cloud ingested into diesel engine

turbo charger intakes and ignited (Macondo)

22 March 2012 A206231 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

22 March 2012 A206231 23

FPSO Case Study

• Incident: Fire and explosion
• Issues:

– Facility Design – Commissioning, QA/QC, carry-over into

• perations

– Competency and training – Control room alarm flooding – Maintenance management

24 A206231 22 March 2012

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

25 A206231 22 March 2012

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

26 A206231 22 March 2012

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

22 March 2012 A206231 27

Any Questions?

www.nopsema.gov.au

28