Emergency response planning
We prepare for the very low possibility of a high-impact event, and have robust plans in place to manage potential incidents.
In advance of our Senegal drilling activities in 2015, we revised our Emergency Response Plan (ERP) to integrate with our contractors, and aligned and improved the Oil Spill Contingency Plan (OSCP). Likewise, and as part of our Management of Change process and in preparation for our 2017 campaign, we again revised the ERP and OSCP to ensure different rigs and vessel capabilities were taken into account. This information was also shared with the regulators in Senegal.
Oil spill in particular remains a high-profile stakeholder concern, and we remain committed to applying the IPIECA-IOGP Joint Industry Practice*, which continued to issue good practice guides in 2016. These are described in our Annual Report and Accounts 2015 and the Oil Spill Resources website, www.oilspillresponseproject.org/. This initiative is recognised across the industry as the most effective and up-to-date response guidance on oil spill.
We continued to invest heavily in memberships to gain access to specialist equipment managed by Oil Spill Response Limited (OSRL) during 2016 and this will continue in 2017. These memberships allow access to a toolbox of different response equipment and techniques, including mechanical containment and surface dispersant application systems, sub-sea systems, and aerial surveillance and dispersant spraying capability. Specialist sub-sea equipment includes the Sub-sea Incident Response Toolkit (SIRT), which enables debris clearance and application of dispersant at or near any well releasing hydrocarbons, and also improves mixing and efficiency of treatment and dispersal. This, in turn, improves amenability to biodegradation of spilled oil. We also have access to a Global Dispersant Stockpile, which consists of substantial amounts of commonly used dispersants that can be drawn on should our supplies run out.
Membership of the Capping Stack System (CSS) allows access to well-capping stacks situated at four strategic locations worldwide. These can be deployed to shut-in a well and prevent oil from escaping into the sea, at which point sub-sea dispersant is no longer needed. We continue to plan for relief well drilling as an option to address such an event. The nature of the response depends on numerous factors relating to logistics and effectiveness.
Changes to response capability
In 2016, we completed the second phase of our exploration and appraisal drilling programme in Senegal and commenced planning for the third phase. With a change in contracting arrangements for rigs, vessels and aviation, we required revision of our emergency response arrangements. This included increasing local capability in our Dakar office by improving the management of our Senegal Incident Management Team (IMT) and also improving the management of our Edinburgh-based Crisis and Emergency Response Team (CERT). We revised our Senegal Emergency Response and Oil Spill Contingency Plans and also made revisions to a number documents previously submitted to Senegal regulators, including: Environmental and Social Impact Assessment; hazard study; hazardous installation document; and emergency plan description. In the Dakar office, we have an Emergency Coordination Centre from which the IMT operates; this centre was refitted to improve communications, including communication with our new supply base in Dakar and head office in Edinburgh, and improved communications technology.
We continued to run CERT and IMT exercises for various emergency scenarios during the year, increasing the range of potential situations to which our personnel may be exposed. Prior to commencing the third phase of our activities in Senegal, the IMT personnel were given role-specific training, including desktop training and a scenario-based exercise involving the drilling rig and the CERT. Our shore-base personnel and our vessel and helicopter crews were also given specialist training for oil spill management purposes. We also maintained our membership of the regional spill organisation, West and Central Africa Aerial Surveillance and Dispersant Spraying Services (WACAF).
Oil spills in 2016
In 2016, we experienced four minor spills with a total of 167 litres spilled to sea. They were the result of ‘flare-out’ incidents during well testing in the phase two drilling programme in Senegal. The incidents arose as a consequence of ineffective rig orientation to the prevailing weather, seawater salting of the flare nozzle and setting the water deluge too high. These issues were addressed early in the campaign and no further problems occurred.
Engaging with partners
We continued to work closely with our joint venture partners, in a non-operator capacity, on our Kraken and Catcher North Sea development projects and progressing them towards first oil and cash flow in 2017. This included working closely with the operators of both projects on the development of their Safety Cases. These documents demonstrate that safety and environmental critical risks of any installation (production platform or rig) have been reduced to As Low As Reasonably Practicable (ALARP). All fixed and mobile installations in the North Sea must hold a Safety Case, a requirement of the 2015 UK Offshore Installation (Offshore Safety Directive) (Safety Case) Regulations, which came into force following the implementation of the EU Offshore Safety Directive in 2015.
UK authorities required our partners in Kraken to submit a Safety Case. As a prudent partner, we supported and reviewed the development of the Safety Case information and document to assure ourselves of progress and completion, and also to identify lessons learned. Lessons learned from the process were shared with our partners for development of the Safety Case for the Catcher development. Such lessons learned will also prove helpful should a floating production, storage and offloading (FPSO) installation be the solution of choice in Senegal, subject to legislation.
We continued to progress development of the management systems for our other operated and non-operated activities in the UK and Norway with ongoing dialogue with Norwegian regulators who require that non-operators assure themselves of the adequacy of their partner operating standards.
*The IPIECA-IOGP Oil Spill Response Joint Industry Practice (OSR-JIP) was set up to implement learning opportunities in respect of oil spill preparedness and response following the April 2010 well control incident in the Gulf of Mexico. As part of this effort, the OSR-JIP has produced more than 20 good practice guides. IPIECA is the global oil and gas industry association for environmental and social issues.