gavin guyan manager - well integrity nopsema. nopsema - drillsafe - march 2012... · key wells...
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Gavin GuyanManager - Well Integrity
NOPSEMA
DrillSafe 1 March 2012
Scope
• NOPSEMA & Legislation 2012– Wells focus
• Industry Performance 2011 – MODU focus
• NOPSA’s functions expanded to include environment protection and general administration and is continued in existence as the National Offshore Petroleum Safety and Environmental Authority (NOPSEMA)
• Creation of National Offshore Petroleum Titles Administrator (NOPTA) to replace the Designated Authorities in Commonwealth waters
• NOPTA is a branch within RET, administer titles and petroleum data and advise the JA
National Regulator Amendments – 1 Jan 2012
• The OPGGS Amendment (Significant Incident Directions) Bill 2011 has just been passed by Parliament
• Enables NOPSEMA to direct a titleholder, in the event of a significant offshore petroleum incident that has caused or might cause an escape of petroleum, to:– take action (prevent, eliminate, mitigate, manage or
remediate) or not to take an action, and – may be unconditional or subject to conditions– The direction may apply either within or outside the
titleholder’s title area
Significant incident directions
• Operations– Offshore petroleum operations– Offshore greenhouse gas storage operations
• Scope– Occupational health and safety– Structural integrity of facilities and wells– Environmental management of petroleum
activities
- Petroleum Safety Zones
NOPSEMA Coverage
Legislation administered by NOPSEMA
• Schedule 3 to Cth OPGGSA
• OPGGS (Safety) Regulations 2009
• Part 5 of the OPGGS (Resource Management and Administration) Regulations 2011 [Wells regulations]
• OPGGS (Environment) Regulations 2009
Commonwealth Offshore Petroleum and Greenhouse Gas Storage Act
2006
[OPGGSA]
Safety Regulations
Schedule 3 – OHS law
Wells regulations
Environment regulations
Environment Regulatory framework (Petroleum)
• Environment Regulations 2009 - Unchanged
• Petroleum activity conducted:– consistent with the principles of ecologically
sustainable development; and – in accordance with an accepted environment plan
that has appropriate environmental performance objectives and standards as well as measurement criteria for determining whether the objectives and standards are met.
Environment Plan requirements include
• Description of the– Activity,– Environment– Environmental impacts and risks– Environmental performance objectives & standards
• Implementation strategy• Reporting and monitoring arrangements
Wells Regulatory framework – Part 5 RMAR 2011
• Performance-based regime that requires the titleholder to control well integrity hazards or risks where integrity means:‒ under control in accordance with an accepted WOMP‒ able to contain reservoir fluids‒ subject only to risks that have been reduced to a level
that is as low as reasonably practicable
• Risks managed in accordance with sound engineering principles, standards, specifications and good oil field practice
Key wells regulatory changes – 29 April 2011
• NOPSEMA replaced the Designated Authority as the regulator for wells
• NOPSEMA decides:‒ WOMP acceptance/rejection‒ individual well activities approval / rejection
• Integrity definition includes that the well is subject only to risks have been reduced to a level that is as low as reasonably practicable
• Part 5 (RMAR) is a listed OHS law => NOPSEMA powers apply
WOMP Regulations – Safety Case for Wells
• Be appropriate • Explain philosophy and criteria; company policies and
processes that are the basis of the design, construction operation and management of the wells
• Identify risks & controls - demonstrate well integrity risks are reduced to ALARP
• Include performance standards, objectives & associated measurement criteria
• Explain how a well integrity hazard or increase in risk will be managed => contingency planning.
WOMP - Core Concepts
• WOMP must:– be appropriate to the wells and well activities
contemplated – be a stand-alone document that is sufficient to meet
the contents & level of detail requirements of the regulations without need to refer to other documents external to the WOMP.
• Only by inclusion of a sufficient level of detail in the WOMP will NOPSEMA be able to make a judgement on the appropriateness of the WOMP in accordance with the regulations
Well regulation challenges
• 30 WOMPs & 146 AAUWAs assessed to date – (4 rejections)
• Relationship between WOMP & AAUWA– Content & Level of detail
• Guidance – Intention to develop a WOMP contents guidance document similar to that used for the SC guidance notes has proved problematic.
• Review of well regs (Part 5 RMAR), with a view to considering revision, is underway.
A safe Australian offshore petroleum industry
-PERFORMANCE
IRF Data
Australia
IRF Countries0
5
10
2005 2006 2007 2008 2009 2010 2011
Rate
Gas Release Rates (per 100 million BOE)
Conservative estimate based on stable BOE 2010-11
0
5
10
2005 2006 2007 2008 2009 2010 2011
Rate
Injury Rates (ADI+LTI)(per million hours )
Injuries
0
5
10
15
20
2005 2006 2007 2008 2009 2010 2011
Rate
TRC Ratesper million hours worked
ALL Operators
ALL MODU Operators
Facility Numbers
Facility Group Based on Current (2011) data *
Platforms 58
FPSOs 14
MODUs 15
Vessels 13
Pipelines 109
TOTAL: 209
Incidents by Facility Type
NB : Incidents includes Accidents and Dangerous Occurrences
0
2
4
6
8
10
FPSO / FSOs Platforms MODUs Vessels Pipelines
Rate
Incidents per Facility per year By Facility Type
2011
Severity of Incidents
• Based on the International Regulators Forum (IRF) severity rating.
• Major is considered more serious, • followed by Significant as less
serious.
Major Incident Rate
Significant Incident Rate
0
4
8
12
16
20
2005 2006 2007 2008 2009 2010 2011
Rat
e (p
er m
illio
n h)
MODU Incident Severity Rates
Accidents & Dangerous Occurrences
Accident Rate
Dangerous Occurrence Rate
0
4
8
12
16
20
2005 2006 2007 2008 2009 2010 2011
Rat
e (p
er m
illio
n h)
MODU Incident Rates
Number of MODU Incidents reported per year
Incident Type 2005 2006 2007 2008 2009 2010 2011Trend 2005-11
Accident - Death or Serious Injury 1 1 6 9 2 1 4
Accident - Incapacitation >3 days LTI 5 10 8 15 10 14 8
Could have caused Death or Serious Injury 9 7 25 22 18 14 11
Could have caused LTI 20 29 24 22 15 12 14
Fire or Explosion 3 4 3 7 1 2 3
Collision marine vessel and facility 4 4 0 3 4 2 1
Uncontrolled HC release >1 - 300 kg 0 0 0 0 1 0 0
Well kick >50 barrels 0 0 0 0 0 1 0
Unplanned Event - Implement ERP 5 0 4 6 6 8 0
Damage to Safety-critical Equipment 0 5 5 7 9 7 6
Other kind needing Immediate Investigation 8 9 12 16 9 8 2
TOTAL 55 69 87 107 75 69 49 Number of MODU Complaints reported per year
Complaints 5 12 17 8 5 6 12 Red = Major Incident Types
MODU Incidents – 2005-2011
Incident Root Causes
Top three TapRoot® Groups for All Incidents2005 2006 2007 2008 2009 2010 2011
Procedures - Not
Followed
Preventive Maintenance
Procedures - Not
Followed
Procedures - Not
Followed
Procedures - Not
FollowedDesign Specs Design Specs
Preventive Maintenance
Mgmt System -
SPAC
Preventive Maintenance
Preventive Maintenance
Design SpecsProcedures -
Not Followed
Procedures - Not
Followed
Design SpecsProcedures -
Not Followed
Design Specs TrainingPreventive
MaintenancePreventive
MaintenancePreventive
Maintenance
0
5
10
15
20
25
2005 2006 2007 2008 2009 2010 2011
MODUs Inspected per year
Inspection Findings - Recurring
• Maintenance Management• Lifting Equipment Management• Lifeboat issues• Client Contractor interface management• Supervisory Competence Assurance
Questions?