Health and Safety Executive

How the HSE regulates

the oil and gas industry

offshore

Paul Bradley CEng, FIMMM, CMgr, MCMI

(Operations Manager)

Health & Safety Executive

Health and Safety Executive’s role

• Britain is one of the safest places to work in the world

• Over 20 years’ experience of regulating the oil and gas industry

on and offshore

• HSE has no involvement in setting UK energy policy or

environmental and planning decisions

• Cooperation with other regulators and public bodies

• Part of the competent authorities SCR 2015 & COMAH 2015

• Operators are responsible for managing risks

• HSE regulates and holds them to account

Repeat the process

for appraisal,

production wells.

Regulatory landscape for Offshore

OGA checks for HSE, Environmental and

Consents, issues well consent

OGA awards exclusive licence and stewardship after open competition

Exploration

well

HSE

• Scrutiny before

operations

• Well design &

construction

• Independent

verification

• Safety of drilling

operations

BEIS • Environmental permits

• Preparedness

• Oil Pollution

• Emergency Plans

• Relief Well

Repeat the process for

appraisal, production

wells.

Regulatory landscape for

unconventional oil and gas

OGA checks for HSE, environmental and

planning consents, issues well consent

OGA awards exclusive licence after open competition

Exploration

well

County Council Planning permission (public

consultation)

Traffic, noise, visual

intrusion, nature

conservation…

HSE

• Scrutiny before

operations

• Well design &

construction

• Independent

verification

• Safety of drilling

operations

EA/SEPA/NRW • Abstraction licences

• Environmental permits Statutory

consultee

Oil and Gas Authority

Applications

UK Oil & Gas Regulations

UK Oil & Gas Regulations

• Health and Safety at Work etc. Act 1974 (HWSA)

• The Offshore Installations (Offshore Safety Directive) (Safety

Case etc.) Regulations 2015

• Offshore Installations and Wells (Design and Construction,

etc) Regulations 1996 (DCR)

• Control of Major Accident Hazards Regulations 1999

• Borehole Sites and Operations Regulations 1995 (BSOR)

• Reporting of Injuries, Diseases and Dangerous Occurrences

Regulations 2013 (RIDDOR)

Goal Setting Legislation

Health and Safety at Work etc Act

1974 (HWSA)

• Based upon the Robens Report on Health and Safety at Work

in 1972.

• Section 2 - Duty of employers to their employees

• Section 3 – Duty of employers and self-employed to those not

in their employment.

• Section 7 – Duties of employees at work

• Section 20 – Powers of Inspectors

HSE’s powers of inspection and

enforcement

• Powers of entry

• Proportionate approach to seeking compliance

• Securing information / investigation

• Improvement Notices

• Prohibition Notices

• Prosecution

The Six Pack

• Management of Health and Safety at Work Regulations 1999

• The Workplace (Health, Safety and Welfare) Regulations

1992

• Provision and Use of Work Equipment Regulations 1992

(PUWER)

• Personal Protective Equipment at Work Regulations 1992

(PPE)

• Health and Safety (Display Screen Equipment Regulations

1992 (DSE)

• Manual Handling Operations Regulations 1992

The Offshore Installations

(Offshore Safety Directive) (Safety

Case etc.) Regulations 2015 (SCR)

Safety Cases revised to include: (assessed by specialist teams)

• CMAPP (Corporate Major Accident Prevention Policy)

• SEMS (Safety and Environmental Management System)

• SECEs (Safety and Environmental Critical Elements)

• IERP (Internal Emergency Response Plan) PFEER & OPEP

provisions together.

• Environmental Information.

• Regulation 11 – Establishment of a well examination scheme.

Offshore Installations and Wells (Design

and Construction, etc) Regulations 1996

(DCR)

• Regulation 13 – No unplanned release of fluids from the well

• Regulation 15 – Design with a view to suspension and

abandonment

• Regulation 16 – Materials

• Regulation 17 – Well Control

• Regulation 18 – Arrangement for examination

• Regulation 19 – Provision of drilling information

• Regulation 21 – Information, instruction, training and

supervision.

Reporting of Injuries, Diseases and

Dangerous Occurrences Regulations

2013 (RIDDOR)

Reporting

• Hydrocarbon Releases

• Injuries

• Fatalities

Investigation

• Based on severity of incident/ injury

• All fatalities are investigated

Control of Major Accident

Hazards Regulations 2015 (COMAH)

COMAH Regulations are based on a Two Tier System:

• Low Tier COMAH Sites

• Top Tier COMAH Sites

• Tier system is based on the quantity in tonnes of the applicable dangerous

substance. For COMAH to apply, a dangerous substance must be present

and equal or greater than the qualifying quantity set out in COMAH

Regulations Schedule 1.

• Can be classed as either ‘Dangerous Substances’ or ‘Categories of

Dangerous Substances i.e. Toxic, Explosive, Flammable’

For example

• Hydrogen: Low Tier: 5 tonnes. Top Tier: 50 tonnes.

• Hence, COMAH Regulations cover gas storage sites such as in salt caverns.

Before work starts

• Safety Case

• Operator Consultation

• Industry Standards / Performance Standards

• Auditing well examination scheme and appointment

of independent well examiner

Well Examination Scheme

• Examination by ‘Well Examiner’

– Any part of a well

– Information on design and construction of well, sub-surface

environment, formations and fluids within them.

– Operations in progress.

• Well Examiner Report

– Findings

– Remedial action

• Provides assurance that the well is properly designed,

constructed and adequately maintained.

The Independent Well Examiner

• Important quality control for the industry

• Independent competent person

• Assess well design, construction and maintenance.

• Review the proposed and actual well operations to confirm they meet the operator’s policies and procedures, comply with HSE’s Regulations and follow good industry practice.

• HSE checks that the operator has these arrangements in place for the complete lifecycle of the well from design through to final plugging and decommissioning.

Design of the well

The life cycle approach

• Well must be designed, constructed operated, maintained

suspended and abandoned so that there can be no unplanned

escape of fluids for its entire life cycle

• Operator must mitigate all risks

• All wells constructed to industry standards with suitable well

integrity and well control

• The well must be designed with decommissioning in mind

Guidelines

Well Life Cycle Integrity Guidelines,

Issue 3 – March 2016

• Well Integrity, Barriers and Well Control

• Well Design and Operations Planning

• Operations (Drilling, Well Testing,

Completion, Commissioning, Intervention)

• Management of late-life and end-of-life wells

Guidelines

Shale Gas Well Guidelines, Issue 3 –

March 2015

• Well Design and Construction (Operations

Planning)

• Well Integrity – Operations (Production)

Phase

• Fracturing/ Flow-Back Operations

• Fracturing Fluids

Well Notification Process

DCR

• 21-days before operations commence, can be 10 by exception

• Scrutiny by HSE wells specialists

• Details of well design

• Programme of work

• Safety equipment and rig to be used

• Assessment of geology and any other nearby workings

• Operators held to account against the notification

Construction of the well

Construction of the well

• Weekly reports.

Contain details of:

– activity since the work started or since the last report

– the diameter and depth of the borehole

– the diameter and depth of the casing

– drill fluid density

• Purpose - to check against information in the notification and that the

pressure in the well and the well’s stability is as expected.

• Further notifications

Operation of the well

Operation of the well

Any operations where there is a chance of loss of control must be

notified to HSE

Specific incidents must be reported:

• A blowout or uncontrolled flow of well fluids

• The use of blowout prevention equipment to control an

unplanned flow

• The unexpected detection of hydrogen sulphide

• Failure to maintain separation distance between wells

• Mechanical failure of any safety critical element of a well

Decommissioning and

abandonment of the well

• Design takes account of decommissioning

• Further notification and weekly operational reports must be

submitted to HSE

• Well to be suspended or abandoned in a safe manner so that

there can be no unplanned escape of fluids from the well or its

reservoir

• Multiple barriers – Primary/ Secondary Cement plugs 500ft

(Combination plugs 800ft), Environmental plug

• Verification – CBL/VDL – Pressure Testing

Abandonment Guidelines

UK Oil and Gas Guidelines for the

Suspension and Abandonment of

Wells Issue 3, 2009

• Requirements of Permanent Barriers

• Verification of a Permanent Barrier

• Special Considerations (Multi-lateral,

H2S/CO2, High Angle/ Horiz. Wells)

• Required Standards for Suspension

• Notifications and Record Keeping

Abandonment Guidelines

UK Oil and Gas Guidelines on

Qualification of Materials for

Abandonment of Wells – Issue 2,

2015

• Requirements of permanent barriers

• Operating conditions

• Functional failure modes

• Material Types

What are the main hazards?

Uncontrolled release leading to

explosion or fire

Not following procedures, good

industry practice examples

• Sub hydrostatic well

• Fishing to retrieve a tool – wireline operation

• No PCE utilised

• Controlled rate of seawater top up stopped for 4

hours

• 900kg of fluids release

• 2 x IN’s served

• MOC

• Training and instruction

Fluids released example

Elgin Franklin G4 Well

A blowout occurred on the Elgin Well Head Platform (EWHP) at approximately 12.30 pm

on Sunday 25th March 2012 during an attempted well kill of well G4. In the first minutes

of the event an estimated 3 to 4 tonnes of high pressure, extremely flammable gas and

condensate was released. Over the following 51 days, until G4 was brought under

control, it is estimated some 6172 tonnes of gas and condensate was released, making

this the largest hydrocarbon release recorded on The HCR database .

At the time of the incident, a jack-up drilling rig was alongside the EWHP. The blowout

had the potential to result in a major fire and explosion, which would have immediately

put the lives of persons on the EWHP at risk.

Well G4 was one of eleven high pressure/high temperature [HP/HT] wells on the Total

E&P UK Limited, owned and operated EWHP. The Elgin / Franklin complex of

installations, of which the EWHP is part, is located in the Central Graben Area of the

North Sea, 240km East of Aberdeen. It consists of the Elgin Process Utilities and

Quarters [PUQ] platform, the bridge linked EWHP and the normally unmanned Franklin

Wellhead Platform [FWHP]. The FWHP is approximately 5.5km South Southeast of the

PUQ and connected to it by a subsea pipeline.

The gas release resulted in the shut down of the Elgin / Franklin facility and the

evacuation of all 238 personnel on board the Elgin and Viking. It also resulted in the

shutdown and evacuation of non-essential personnel from the neighbouring Shearwater

platform and Hans Deul drilling rig, operated by Shell and Noble respectively, and led the

Coastguard to impose a two mile shipping and aircraft exclusion zone around the Elgin

platform.

Elgin Franklin G4 Well

Total had experienced an increasing problem of high pressure gas from the Hod

formation leaking into well annuli [i.e. the voids between the concentric well casings] of

wells in the Elgin / Franklin field. The gas was known to be entering the annuli through

failures in the well cement and casings. This phenomenon, known as sustained casing

pressure (SCP), is an indicator of well integrity problems and left unmanaged can result

in casings being over pressurised. Ultimately SCP can result in a surface or subsea

blowout from a well.

Well G4 first developed SCP in 2004, as a result of cement and casing failures. Total

managed the SCP in G4 and other wells, by bleeding-off pressure from the annuli to

maintain them within defined safe operating windows, referred to as the Annulus

Management System (AMS)

Tthe frequency of bleeding from the ‘A’ annulus (i.e. the void between the production

tubing and the production casing) increased significantly to maintain it within its operating

window. Total were concerned that this increased frequency of bleeding was a threat to

the integrity of G4. As such they decided to stop all bleeding and to allow the ‘A’ annulus

pressure to rise to and balance against the influx pressure from the Hod. However, this

didn’t adequately address the risk in particular the potential consequences of a failure in

the production casing on the integrity of the well.

Elgin Franklin G4 Well

On 25th February 2012, the G4 production casing failed, followed shortly afterwards by

failure of the intermediate casing. This left G4 with the surface casing as the only

remaining barrier in place to prevent gas escaping from the well.

Total responded to the casing failures by setting up a task force to plan and deliver a well

intervention to kill G4 as a matter of urgency. The well kill began on the 15 March.

However, the well kill did not go according to plan, with a number of additions and

modifications introduced to address un-anticipated behaviours in the well.

Control of the well was progressively lost until, on the 25 March the pressure had

increased to the point where the surface casing failed, releasing gas and condensate at

the wellhead. Fortunately, the release did not ignite and a favourable wind direction

carried gas away from the PUQ and Rowan Viking.

Elgin Franklin G4 Well

• Directed review of the Safety Case

• Changes in Company Management Systems;

• Updated details of HP/HT wells and their

management [to demonstrate SFAIRP that an

unplanned release is prevented];

• Updated risk assessments [taking into account

the lessons learnt from the blow out.

• Prosecution: Total fined £1.125M DCR R13 (1)

Summary - Questions posed ????

• How do the regulated firms manage compliance and how do the

regulators learn about the firm’s practices? (e.g., whether and

how the regulated entity submits a plan to the regulator, receives

consent, and confirms the plan’s execution and performance).

• How is compliance monitored and assessed? What qualifies as

evidence of the risk-controlling benefits of the regulatory regime

and as well as evidence of costs and associated problems?

• What level of variation is permitted among firms and according to

local conditions?

• What capacities do different regulatory approaches demand in

terms of regulators’ autonomy, staff competencies, and funding

sources?

• What technical and performance demands do different

regulatory approaches place on the industry by the regulatory

regime?