Managing new expectations with Enhanced Tier I capability

With every project relating to petroleum activities, the operators in Australia are required to submit an Environmental Plan to NOPSEMA or Department of Mines and Petroleum (DMP) depending whether they are operating in commonwealth or state waters respectively. The plan will identify the risk involving the activity and show that the operators have the capability to manage a worst case oil spill scenario to decrease the impact to as low as reasonable practicable (ALARP). Each spill scenario is classified according to their severity and impact on the environment, based on the spill quantity and amount of resources required for the response. (Table 1)

Oil and gas operators are required to be the lead response agency for any oil spill incident relating to petroleum activities in the commonwealth waters. In order to achieve that, operators should have a first strike oil spill response capability which includes equipment and trained personnel, and have contracts in place to seek the assistance of oil spill response organisations like Australian Marine Oil Spill Centre (AMOSC) and Oil Spill Response Limited (OSRL). Oil and gas operators will have to set their own standards to determine what level of preparedness is deemed sufficient and justify it based on their operating environment and scale of operations.

Chevron ABU has projects concentrated at the Northwest shelf of Australia. The region has a number of significant environmental features, including Barrow Island Class A Nature Reserve, Barrow Island Marine Management Area, and Thevenard Island Class C Nature Reserve. Marine animal species include humpback whales that migrate seasonally through the area, whilst other whale species that occur in the region include Minke whales, Sperm whales and Pygmy Blue whales. Dugongs occur in the shallow waters of the region, turtles nest on coastal and Island sandy beaches and seabirds nest and breed in the region. These make any oil spill incident disastrous if not properly managed.

With the upcoming Gorgon and Wheatstone projects, there will be more than 90 vessels of various classes operating in the area during the construction phase. The vessels themselves present an oil spill risk in the shape of the bunkers that they carry on board as well as their actual activities. The biggest pipe-laying vessel, Solitaire, carrying over 600T of heavy fuel oil, posed the major risk in the area. There is also an ongoing drilling and exploration project in the vicinity which increases the overall risk profile of the area.

Acknowledging the changing risk profile of the business and the sensitivity of the operating environment, Chevron engaged an external third party, OSRL, to conduct a capability review of the current situation and provide recommendations to meet the changing needs.

Despite having some shoreline and near-shore equipment on the islands, there was no equipment for offshore containment and recovery or dispersant operations. Since the operators have the responsibility to be the lead response agency, they should be equipped with the necessary Tier I equipment to perform the basic first strike response strategies. Moreover, due to the sensitivities of the habitats in the operation vicinity, it is best to be able to contain the spill offshore and minimise any shoreline impact.

Time is a critical factor in responding to any oil spill incident. The ability to get support and resources to site quickly will definitely reduce the potential impact on the environment and hence determine the success of the response. Although there are contracts in place for Tier 2/3 support, there may be delays due to the remoteness of the islands and the special quarantine regime of the area.

Barrow Island and Thevenard Island (Figure 1) are 116km and 22 km away from mainland Western Australia (Onslow being the nearest township). The main means of getting equipment to the island is via barge or vessel from Dampier which takes more than 12 hours. Once the equipment arrives on the islands it can then take an additional 48 hours in quarantine before arriving on site and being response ready. In addition, getting external expertise for assistance may be a challenge with accommodation being limited and charted flights to the islands which can take at least 2 hours from Perth.

There are also many remote islands in the region such as the Montebellos and Southern Islands which may be impacted during an oil spill incident. These islands are deserted and getting resources onto these islands to start and maintain the response is definitely a challenge.

Instead of settling with a basic Tier I preparedness, Chevron has chosen to enhance their preparedness by developing an enhanced Tier I concept to address the major issues arising from the remoteness and sensitivity of the areas. An enhanced Tier I concept requires the operator to be self sufficient for the first 48 hours of the response before external assistance arrives. This concept not only involves getting more equipment, but also making use of the resources on the island to facilitate an effective and efficient response. Being self sufficient is important due to the limitations of the environment and the difficulties in getting external assistance to site. There are three aspects to consider:

• Spill Quantity

  According to WestPlan-MOP, a Tier 1 incident is defined as 0-10T of oil spilled. The WestPlan-MOP considers best practice for all operators is to equip themselves with one offshore system, one dispersant system and one shoreline equipment each as part of their preparedness for an oil spill. Since the new regulations state that the operators are now the response agency, operators have to reevaluate whether this equipment is sufficient to match the risk that they have and demonstrate that they have reduced the risk to “as low as reasonably practicable” (ALARP).

  Although it is the responsibility of oil and gas operators to manage any petroleum related incident, they are not oil spill response organizations. It is not possible for any oil and gas company to manage a spill of significant impact solely. Management needs to agree on the level of preparedness within the company and come up with contingency plans to engage external support for spills of significant scale, such as a well blowout, and work out how to integrate these support agencies into their response management systems.

  Chevron ABU in considering their risk, environmental constraints and operational limitations, and decided to build their internal capability to respond to incidents of moderate low significance (i.e. Tier 1+) as classified in their Environmental Plan. This involved getting in additional sets of offshore and shoreline equipment. Oiled wildlife response is a concern as well due to the sensitivities of the environment. Environmental specialists on the island are trained as fauna handlers and contingency plans are made to transport oiled wildlife to the mainland for triage and treatment. For large scale incidents, this enhanced Tier 1 capability will enable Chevron to manage a spill as a first strike while waiting for the arrival of additional resources from AMOSC or OSRL or other resources through the activation of the mutual aid contract.

• Equipment & logistics

  During the capability review, two consultants visited Barrow Island and Thevenard Island to look at the conditions of the equipment on site and speak to the site management on the logistics arrangements. As each operating environment is very different, a range of equipment was recommended. Some of the recommendations included upgrading the skimmers, purchasing rapid deployment offshore containment systems, increasing the length of shoreline boom to increase the area of coverage for protection.

  Due to the special quarantine regime in the vicinity of Barrow Island, vessels have to undergo wet side and top side compliance to enter the Barrow Island marine management zone and new equipment going onto the island has to undergo stringent quarantine checks. These requirements will be a challenge for a time critical response. Logistics preparedness like identifying the vessels of opportunity working in the vicinity which are able to perform oil spill operations and discussions with quarantine department regarding how to better manage the quarantine process is in progress so as to find solutions to speed up the mobilisation timing.

• People

  The workforce on the islands is the major asset to the team. Currently there are approximately 5000 employees on Barrow Island mainly involved in the Gorgon LNG Construction Project. Selected personnel are trained to performed specific roles like conducting shoreline assessment, aerial surveillance and running Incident Command System on site. These trained individuals can then be the first responders on site or deployed to site in an emergency.

  These personnel are selected based on their existing skill sets, such as being environmental specialists or mariners. Their knowledge of the surroundings and experiences from their daily job function can then be fully utilized whilst performing these tasks. As the island operates on a rotational basis, the back to back of these key stakeholders has to be trained to the same standard. This group of individuals forms the Emergency Response Team (ERT) on the island. There is a training matrix that is being developed to match the individual roles with the type of trainings they require. (Table 2) There is also a system in place to track the minimum manning standard of people with the specific skill sets on the island to ensure response readiness.

  Training is conducted by experienced personnel from AMOSC and OSRL to ensure the quality of the materials. Frequent involvement of the trained personnel during exercises is a good way to keep their oil spill knowledge fresh and allows on the job practice in peace time. Thus, individuals will have a better appreciation on the importance of his or her role during an emergency.

  As for the general contractors, they can be taught techniques of shoreline clean up and protection so that they can be guided by the trained personnel during an emergency to provide manpower for the cleanup operations.

Developing and implementing the Enhanced Tier 1 concept is a one year project. There are milestone checks every quarter to ensure progress and that improvements have been completed. The Emergency Process Advisor (EPA) is the nominated custodian of this project and is responsible for updating the management on the progress and request for additional support if needed.

Within six months into the project, there is a clear change in the status of preparedness and readiness of the organisation. More than AUD 2M has been invested in equipment to cover all response strategies and training is being conducted to equip the personnel with specialised skill sets required to perform tasks like conducting oiled shoreline assessment and aerial surveillance. There are more engagement activities with the remote operational sites to get feedback and enhance the communications between the asset and installation management teams. There are also table top and deployment exercises planned to test the progress of the project and identify the areas for improvements.

There should be a continuous improvement plan to revisit the planning cycle again when the risk profile changes. Refresher courses and audits can be conducted to ensure that the personnel and equipment remains at a state of readiness.

The enhanced Tier 1 concept is an inward facing activity to allow operators to build up their internal capability. One should not minimise the importance of engaging external stakeholders to complete the whole picture for oil spill preparedness activity. For an incident with significant impact, mutual aid and cooperation between industry, government and oil spill response organisations are essential. Building up this mutual trust and communication during peace time is crucial.

Chevron ABU has taken a proactive step towards outward facing engagement with other operators. ABU takes the lead to assemble and form industrial functional groups to discuss different response related issues like dispersant operations, waste management and spill trajectory modelling. Environmental experts are gathered to share experiences, findings and issues that they faced in their organisations and everyone can benefit through peer learning. This engagement will facilitate the building of mutual trust among industrial players and enable them to have a better understanding of the whole operating picture in the region.

There are also consultations and involvement of regulatory bodies like NOPSEMA, AMSA, APPEA and oil spill response organisations like AMOSC and OSRL during workshops and when drafting Environmental Plans. This is to ensure the expectations are realistic and achievable. Constant engagement with these organisations allows Chevron to demonstrate their commitment in oil spill response preparedness.

With the changing expectations of the regulators and the rising awareness with regards to oil spill preparedness across the world, operators have to react to the new standards with an open mind and adapt these best practices to suit their operating needs. Only with the cooperation between operators, government and the oil spill response organisations, can we achieve a higher level of preparedness and state of readiness to combat any unforseen incident effectively and efficiently.