UK Action on Oil Spill Prevention and Response Continues Apace
December 2010
By Mark McAllister, Chairman of OSPRAG
The Macondo well incident in the Gulf of Mexico was a tragic event and one understandable reaction was for many to seek reassurance about the safety of deepwater offshore oil and gas exploration. The work of OSPRAG, the UK’s oil spill prevention and response advisory group which was established shortly afterwards to respond to these concerns, is now well underway, and here the group’s chairman, Mark McAllister, updates readers on the work carried out since by the industry, regulators and trade unions to ensure the regulatory regime under which we operate in the UK continental shelf (UKCS) remains fit for purpose.
Robust regulation
The offshore oil and gas industry in the UK is controlled by a rigorous environmental and safety regulatory regime and has a long history of safe drilling operations with over 11,000 wells having been drilled over the last 40 years.
The safety regime, which was built upon the recommendations of the Cullen Inquiry into the Piper Alpha incident in 1988, is fundamentally different to that in the USA with a clear separation in regulatory function between licensing (Department of Energy and Climate Change) and safety (Health & Safety Executive).
A goal setting rather than prescriptive philosophy is delivered through the safety case to ensure that major accident risks are evaluated and reduced to as low as reasonably practicable. Furthermore, the safety case regime obliges the UK industry to review its existing arrangements in the light of new information, such as that learned from the Macondo incident.
The incident in the Gulf of Mexico represents a significant departure from the UK industry norm and in understanding what happened and what the implications might be for drilling in the UK an expert, impartial and thorough approach is critical. The very structure of OSPRAG, with the involvement of the UK regulators and trade unions as well as industry representatives, ensures that this approach is being taken.
Expert approach to prevention
The regulatory regime under which UK oil and gas companies operate is focused first and foremost on the prevention of major incidents and this was the most sensible starting point for a review of practices. OSPRAG’s Technical Review Group (TRG) first embarked on a review of the way in which well examination, verification and primary well control are carried out. It also looked at the use of blowout preventers, as well as competency, behaviours and other human factors.
The work concluded that there is a high degree of confidence in the regulatory regime. It also identified many areas that could be held up and followed by companies across the industry as best practice in preventing loss of well control. Oil & Gas UK has created the new Well Life Cycle Practices Forum for drilling managers, well engineers and designers to share best practice, working closely with the HSE, the unions and other regulators.
The classification of oil and condensate wells by type, pressure, flow-rate, water depth and capability to sustain flow, is also being carried out to improve clarity of information about all wells on the UKCS.
Major progress in enhancing oil spill response
While there is strong confidence in the regulatory regime and practices designed to prevent oil spills from happening in the first place, the industry in the UK is not complacent and has already taken major steps towards augmenting its response mechanisms.
Firstly, the capacity to contain an oil spill was boosted in October, when the industry’s shared oil spill response capability, OSRL (Oil Spill Response) in Southampton, received delivery of two oil containment devices from the Gulf of Mexico. This equipment was developed as key components in systems to help capture and manage the oil flowing from the Macondo well in the Gulf of Mexico. The associated subsea cutting equipment (diamond wire cutting tools and shears) is also now based at contractors’ premises in Aberdeen.
Secondly, significant progress is being made towards securing a capping device for use in the UKCS. In October, the industry agreed to take the conceptual designs developed by engineering services firm Wood Group Kenny to the detailed design stage for the development of a full/partial pressure capping device, which could close off or cap the well and prevent oil from leaking into the environment. This modular system is considered to be the most appropriate solution given the weather conditions typically found in the UK, and specifically to the west of Shetland. Importantly, the work may inform the development of a longer-term regional or global (non-US) response which is being coordinated by the Global Industry Response Group (GIRG) under the International Association of Oil & Gas Producers (OGP).
Capping device: the finer points
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Can be installed at various points of the subsea well head, blowout preventer and lower marine riser (LMRP) assembly to stop the flow of oil.
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Needs to be compact, relatively low weight and flexible for ease of handling and installation in short operational weather windows.
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Modular in concept and likely to utilise a variety of adapters, connectors, a main body incorporating two gate valves, choke and kill manifolds and a variable flow ported sub/cap.
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Rated for 15,000psi working pressure and could be deployed in sea states of up to 5 metres, depending on the vessel used.
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Capping could be achieved within 20 to 30 days of the incident, depending on weather and well site conditions.
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Estimated manufacturing time is currently 11 months but there is a possibility of shortening this once the final equipment configuration is agreed and priorities are set. -
The exact cost of this piece of equipment is yet to be determined but should be in the region of £6 million.
Two additional projects which aim to assess and enhance, where appropriate, the industry’s capacity to respond to an oil spill are also underway.
To evaluate the physical deployment of response equipment, OSPRAG’s Oil Spill Response Group (OSRG) is liaising with the Maritime and Coastguard Agency (MCA) on arrangements for a comprehensive national oil spill response exercise to be held west of Shetland in May 2011.
The arrangements for financial response to an oil spill in the UK are also being reviewed. At the recommendation of OSPRAG’s Indemnity and Insurance Group (IIG), the Offshore Pollution Liability Association Ltd (OPOL) which administers a voluntary industry mutual agreement requiring each operator to accept strict, ‘no fault’ liability for pollution damage and reimbursement of public authorities for remedial measures up to a pre-determined limit, increased that limit to $250 million. This came into effect on 1 October 2010.
All UK operators are OPOL members, thus providing assurance to the Government of an operator’s financial responsibility to the predetermined level in the event of an incident. However, if there is a default on payments, under the OPOL mutual agreement, the rest of the industry will step in to pay third-party costs up to the pre-determined limit. The new limit is sufficient to cover the third party costs of an oil spill in previously modelled spill scenarios.
Further modelling work is now underway using well blowout scenarios at six different locations around the UKCS to determine probable oil spill trajectories and landfall destinations.
