Inspections – Other Areas Other Areas –Interface documents between operators & contractors –EMS – review previous EMS audit report –Heli-Fuel Skid – condition as often exposed –ODS/F-Gas – new legislation Pigging Operations –Are pigging areas bunded? –Are areas clean – any evidence of oil/wax outside bunded area? –Pipeline Integrity DECC Presentation Inspections

Reporting Self Reporting –PON 1 –Non-compliances – OPPC, OCR, PPC, F-Gas/ODS –Permitted Discharge Notification –PON 2 Aerial Surveillance Satellite Surveillance Whistleblowers DECC Presentation Reporting

PON1 Report Pollution Report Requires: Reporter Details Installation / Location Details Type of Spill – oil / chemical Amount Spilled Spill Ongoing – Y/N Source of Pollution Cause of Pollution Steps being taken Will it reach Median Line? Weather Conditions Electronic PON1 now in use

Examples Diesel spill during bunkering Paint spilled while changing tip of spray gun Oil in Produced water > 100mg/L and bad sheen outwith 500m zone Hydraulic actuation valve wears and releases more chemical than normal 100L diesel spilt to deck and washed to recoverable drains system Permitted to use 12T of chemical but used 13T DECC Presentation Reporting Oil PON1 Chemical PON1 OPPC NC & PON1 PDN Chemical PON1 Neither – provided no sheen outwith 500m and recovery system working – then NC Not OCR NC

DECC Presentation Aerial Surveillance

DECC Presentation Aerial Surveillance

DECC Presentation Satellite Surveillance

DECC Presentation Satellite Surveillance Oil Sheen Hit: 11.4 x 0.15 km (1.6km 2 ) – from sand wash discharges at night

DECC Presentation Spill Statistics 2004 – 10

DECC Presentation Spill Statistics

DECC Presentation Investigations What do we Investigate Size, scale and nature of spill Environmental impact and potential impact Location of incident, e.g. special area of conservation or other environmentally sensitive area Permit holders / operators past performance Seriousness of any potential breach of the law Notification that may give rise to public concern or media interest Potential for offshore investigation by DECC – Statement Taking

DECC Presentation Enforcement Enforcement action in line with DECC Enforcement Policy Warning Letter Enforcement Notice Prohibition Notice Prosecutions Revoke Permit Revoke Licence

DECC Presentation Investigations Common Factors and Learning Routine Operations Reinforce Risk Assessment procedures Procedures ‘not followed’ or ‘not in place’ Review competency and training Ensure roles and responsibilities are understood Communication failures Maintain ownership of task Equipment failure / lack of maintenance Operator error Lateral learning within / between companies Post incident Implications

DECC Presentation Investigations Kittiwake – 4 April 2007 Reported loss of 100bbls (19T) crude from parted hose between tanker and platform Vessel lost position and hose ruptured Potential to spill 94m 3 (110T) from 3km pipeline Surveillance aircraft mobilised – 2 hour ETA SBV struggled to spray dispersant due to damaged hose Caused by inexperienced officer of the watch failing to understand / respond to DPS instrumentation / alarms

Clair 22 March 2007 Release of 4.3 tonnes OBM during bunkering operations Failure of Straub coupling on hard piping between loading station and mud pits Poor design selection Couplings not recommended for hydrocarbon service Seals not suitable for hydrocarbon service BP selection criteria not followed DECC Presentation Investigations

Beatrice Alpha 24 April 2008 & 3 June Spills of approx. 300 litres Poor start up procedures Lack of WEMCO level control Passing valves Crude formed tarry balls on sea surface Washed up on coast within 1-2 weeks Extensive clean up required by operator DECC Presentation Investigations

Jade 27 October 2009 Release of 6 tonnes diesel during bunkering operations Faulty interlock valve stuck in open position Poor procedures Operating practices between Jade/Judy unclear EC equipment not identified Need to review operating practices & philosophies Review Environmentally critical systems & provide additional training DECC Presentation Investigations

DECC Presentation Environmental Reps What can Environmental Reps do Site Audits – drains, hoses, ECE, weeps/seeps, bunds, etc Involvement in Investigations Reinforce Environmental / Regulatory message to offshore staff Encourage Environmental aspect to Safety Observation Systems Encourage cross learning intra-company DECC inspection preparation Meet with DECC inspectors

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