Supplementary Guidance on the Reporting of Hydrocarbon Release, Issue 3 January 2016

HCR Reporting Guidance Revision History Issue 3 December 2015, replaces the previous Issue 2 and includes the following changes: Industry feedback & comments Reportable limits for wells and pipeline releases Case study examples for non-petroleum hydrocarbon, wells and pipeline releases Reporting requirements for releases with unintended consequences (see Case Study Example 6, release case was previously not reportable now RIDDOR reportable) EU Implementing Regulation reporting requirements EU reporting requirements in the case study examples

HCR Reporting Guidance Accompanying Documents EU, Guidance Document on Commission Implementing Regulation (EU) No. 1112/2014, as available on the OSDR website at the time of publishing this O&GUK guidance OSDR, Revised Guidance on reporting offshore hydrocarbon releases, version 7.2 (Guidance on how to complete the reporting form), as available on the OSDR website at the time of publishing this O&GUK guidance HSE, Dangerous occurrences, HSE, Guidance on RIDDOR reporting, Operations Notice 30,

HCR Reporting Guidance Contents Overview Section 2: Regulatory Requirements for RIDDOR & EU reporting Sections 3 to 6: The methodology for determining whether a release is RIDDOR reportable Section 8: Case studies (includes both RIDDOR and EU assessments) Appendices: Reporting Requirements Consequence Analysis Application of Methodology to Non-Petroleum Hydrocarbon Fluids High Water Content Liquids

HCR Reporting Guidance Regulatory Requirements RIDDOR: Release of petroleum hydrocarbon 75 The unintentional release of petroleum hydrocarbon on or from an offshore installation which – (a) results in – (i) a fire or explosion; or (ii) the taking of action to prevent or limit the consequences of a potential fire or explosion; or (b) could cause a specified injury to, or the death of, any person.

HCR Reporting Guidance Regulatory Requirements EU Regulation: Reporting requirements and definitions differ from RIDDOR and are given in Guidance Document on Commission Implementing Regulation (EU) No 1112/2014. Table 3 provides clarity on the EU fluid types and the corresponding RIDDOR fluids and dangerous occurrences Table 4 provides clarity on the EU reportable limits and reporting requirements and the corresponding limits and requirements in RIDDOR. Introduces the term “fugitive emissions”. Due to the different reporting requirements for EU and RIDDOR occasions will arise when a release will be reportable under the EU Regulation but not under RIDDOR and vice versa.

HCR Reporting Guidance Fugitive Emissions Fugitive gas emissions: Gas releases arising from loss of tightness from hydrocarbon containment equipment such as valves, flanges and other connections, pressure relief devices, process drains, open-ended valves, pump and compressor seal systems, agitator seals, and access door seals. EU reportable limit: ≥ 3 kg/hour and ≥ 1 kg released Non-fugitive gas emissions: Gas releases due to causes such as corrosion pinholes or cracks in process containment systems. EU reportable limit: ≥ 1 kg released

HCR Reporting Guidance Fugitive Equivalent Liquid Emissions Fugitive equivalent liquid emissions: Liquid releases arising from loss of tightness from hydrocarbon containment equipment such as valves, flanges and other connections, pressure relief devices, process drains, open-ended valves, pump and compressor seal systems, agitator seals, and access door seals. EU reportable limit: ≥ 100 kg/hour and ≥ 60 kg released (except methanol) EU reportable limit: ≥ 80 kg/hour and ≥ 60 kg released (methanol) Non-fugitive equivalent liquid emissions: Liquid releases due to causes such as corrosion pinholes or cracks in process containment systems. EU reportable limit: ≥ 60 kg released

HCR Reporting Guidance Fluid Equivalents

HCR Reporting Guidance RIDDOR DO 75 - Amendments “Confirmed” Guidance clarified to state: Once a suspected release is confirmed, the evidence that first gave rise to those suspicions (process trends, fire & gas detector logs, smell etc.) should be used to estimate the release duration. Unintended Consequences Unintended consequences relate to an intentional gas release, which is considered a safe operation, such as release from a vent, but escalates to the extent where immediate actions in addition to the arrangements for safe operation result either automatically or are required by manual intervention to reduce risks. Releases with unintended consequence such as these are reportable. See Case Study 6.

HCR Reporting Guidance RIDDOR & EU Reporting Flowchart