Oil Spill Response Lessons for UK following Macondo Incident

Craig Bunyan Senior Inspector

Why Respond?

Harbour authorities, operators of offshore installations, owners and masters of ships bear the primary responsibility for ensuring they do not pollute the sea National Contingency Plan Regulatory Requirements Stakeholder Reputation/Public Perception Significant Cost Implications Moral Obligation

Pre-Macondo

International Convention on Oil Pollution Preparedness, Response and Cooperation 1990 (OPRC)

The Merchant Shipping (Oil Pollution Preparedness, Response and Cooperation Convention) Regulations
The Offshore Installations (Emergency Pollution Control) Regulations 2002 SOSREP OPEP Regulatory Guidance Reviewed with industry and updated in 2009 Regular training exercises

April: Macondo Incident

Could it happen here in the UK?

Is your Company/Organisation prepared? Is your OPEP fit for purpose and staff ready and able to respond ? Is the UK prepared and able to respond? Reviewed arrangements in light of above

April: Macondo Incident (cont)

Current OPEP Guidance viewed as robust and enabled operators to produce an OPEP which is a fit for purpose operational document which sets out clear procedures to respond to offshore oil pollution incidents
However: Letter with revised Guidance to industry sent 23 December 2010; Letter with further guidance sent to industry 21 July 2011 both are considered to be interim guidance to further strengthen arrangements Future: US reports + Review of UK Regulation + OPEP Work Group output = Revised OPEP Guidance

January 2011

Following an enquiry by The Energy and Climate Change Committee into the Deepwater Horizon incident, an announcement was made that: companies should not produce cut and paste oil spill response plans; and

offshore industry need to revisit scenarios they previously thought were too extreme and unlikely to occur
DECC now require additional information within Oil Pollution Emergency Plans to provide evidence that systems and procedures are in place to allow both Operator personnel and Contractor personnel to respond effectively to a major oil spill situation.

Post Macondo

Re-confirmed that primary purpose of OPEP is to inform operator, to allow implementation of a robust, effective and tested emergency response procedure. All OPEPs must assess, and provide for an effective response to, an identified worst case scenario where all containment barriers have failed resulting in a blow-out, which would normally result in the requirement for a relief well to be drilled. Initiated Exercise SULA in May 2011 to test the UKs National Contingency Plan

Post Macondo

Re-confirmed modelling used to determine likely areas of any environmental impact - clarification given OPEP to detail response strategy to manage the incident and protect the environment further information added Operator must have systems and procedures in place to source and initiate contract for controlling the well situation details of time taken to source and deploy equipment Confirmation of operators financial position or insurance provision to cover costs of drilling relief well and responding to spill

Post Macondo

Activities are, and always were, assessed on case by case basis however DECC may require additional information to provide necessary level of assurance that: all necessary measures have been taken to manage the activities, the environmental aspects, and compliance with the environmental regulations and related approvals; actions have been taken to mitigate the risk of environmental incidents; and sufficient pollution control and response arrangements are in place in the event of an incident

Post Macondo: DECC & OSPRAG OPEP Sub-Group

DECC is working alongside industry within various sub-groups: Gap analysis between current OPEP Guidance and existing/proposed (toolkit) and issues identified by industry Guidance updated Taking into account Macondo reports, exercise SULA , NCP and regulatory review Liaising with other applicable OSPRAG subgroups and incorporate future strengthening into OPEP Guidance i.e. aerial surveillance; modelling; use of dispersants; containment and recovery; waste management , etc Investigating potential for shared web site to access response information Aim: Develop, strengthen, update and implement Regulatory OPEP Guidance and produce an industry operational response best practice document

Prevention is Better Than Cure!!!