Strategic approach to managing safety and environmental critical elements (SECEs)

Working together for a safer world

Strategic approach to managing Safety & Environmentally Critical Elements (SECEs)

Ian Thomas, September 2015

©Lloyd’s Register Consulting

Introduction

It is a requirement Offshore Directive 2013/30/EU that operators and owners

establish schemes for independent verification of safety and

environmentally critical elements (SECEs)

In the UK, follows requirement for closer integration for management of

environmental impact and major hazards specified in SCR 2015:

• Regulation 9 (Establish scheme and written record of SECEs)

• Regulation 8, Schedule 3 (Integrated SEMS)


Focus

This presentation shall focus on:

• Major accident hazards and the environmental element within the SECEs

We shall look at identification and management of SECEs:

• Definitions and considerations

• Quantification and impact assessment

• Key steps in the identification process

• Management and assurance

• How we can support you.


Focus

We are concerned with Environmental incidents as

defined by EU Directive / SCR 2015.

Environmental incidents within scope must exhibit

two key characteristics:

1. Related to major accident

2. Exhibit significant & lasting environmental

damage.


Definitions – major environmental incident

1) An environmental incident resulting from any event referred to in

paragraph (a), (b) or (d) in Reg 2 of SCR 2015.

a) fire, explosion, loss of well control or the release of a dangerous substance

b) major damage to the structure

c) Failure of life support for diving operations

d) death or serious personal injury to five or more persons

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Definitions – Significant & lasting environmental damage

2) An environmental incident is further defined in terms of significance and lasting

damage. That is, an incident which results, or is likely to result, in significant adverse

effects on the environment in accordance with Environmental Liability Directive

2004/35/EC

Environmental damage to the following:

a) damage to protected

species and natural

habitats.

b) water damage, which is any damage

that significantly adversely affects

the ecological, chemical & amenity /

commercial status.

c) land damage, is any land

contamination that creates a

significant risk to human health

Damage means a measurable adverse change relative to

baseline condition


Definitions – significant & lasting environmental damage

Further guidance regarding definitions regarding lasting damage and setting of

thresholds for an environmental incident can be located in:

a) The Habitats Directive 92/43/EEC regarding conservation of natural habitats and of

wild fauna and flora

b) Birds Directive 79/409/EEC

c) Water Framework Directive 2000/60/EC regarding water damage


Considerations for quantification when setting thresholds

Oil spill scenarios & response Times < 25 miles from beach

Oil Quantity (Estimate)

Oil Type

Aerial Surveillance Capability

Block Specific Vulnerability (JNCC 1999)

1 (very high vulnerability) All other categories (high, moderate and low vulnerability

0 to 25 tonnes 1 Within 4 hours

Monitor and natural dispersion – (dispersant requirement assessed on case by case basis)

Monitor and natural dispersion - No dispersant requirement

2; 3 and 4 Monitor and dispersant within 1 hour

Monitor and dispersant available but no “within 1 hour requirement”

25 to 100 tonnes 1 Monitor and natural dispersion – (dispersant requirement assessed on case by case basis)


2, 3 and 4 Monitor and dispersant within 2 hours

Monitor and dispersant available but no “within 2 hour requirement”

100 to 500 tonnes

1 Monitor and natural dispersion – (dispersant requirement assessed on case by case basis)


2; 3 and 4 Monitor and dispersant within 6 hours

Monitor and dispersant within 6 hours

>500 tonnes 1 Monitor and natural dispersion – (dispersant requirement assessed on case by case basis)


2; 3 and 4 Monitor and dispersant within 18 hours

Monitor and dispersant within 18 hours

Type of hydrocarbon inventory and proximity to shoreline

ITOPF classification / Oil type

1. Group I SG < 0.8 e.g. Kerosenes / Gasolines

2. Group II SG 0.8-0.85 e.g. light crude, gas oils

3. Group III SG 0.85-0.95 e.g. medium crude

4. Group IV SG> 0.95 or Pour Point > 30 degree

International Tanker Owners Pollution Federation

Limited (ITOPF)



Physical and chemical properties of hydrocarbon

• Viscosity

• Mobility

• degradability,

• molecular weight

• Toxicty

• Ability to bioaccumulate biomagnification

• Ability to react with other substances / synergistic

effects etc).



Metocean factors

• Weather and sea state conditions

• Hydrographic conditions

Seasonal and temporal factors

• Time of year and time of day (breeding / migration seasons)

Special Areas under MARPOL Annex1 in the North-East Atlantic OSPAR Maritime Area



Example: Impact quantification The level of harm that would constitute a Major Accident to the Environment (MATTE) is defined as follows: a) 2 ha or more of contamination to the littoral or sub-littoral zone; b) 100 ha or more of open sea benthic community; c) 100 or more dead sea birds (500 or more gulls); d) 5 or more dead/significantly impaired sea mammals

Source Chemical and Downstream Industries Forum (CDOIF) 2014; reflecting: • Seveso Directive • DETR 1999 COMAH regulations

Guidance available, but there are no prescriptive thresholds.


Stage 1: Identification of SECEs with safety function

Identify Major Accident Hazards using safety case

Identify system (structure, plant & IT) which can cause, prevent, detect, control mitigate, rescue or help recover from a major

accident

Identify systems for prevention of fire and explosion and emergency response

Record items identified as SECEs (Safety)

Stage 1

Use existing guidance to

Identify structures, plant,

equipment and IT as safety

critical.


Identify MAHs

Identify Major Accident

Hazards

• HAZID

• Safety Case

Major Accident Hazards HC.001 Loss of containment from Production Riser/ Turret System HC.002 Loss of containment from Crude Separation/ Stabilisation System HC.003 Loss of containment from Gas Compression System HC.004 Loss of containment from Gas Dehydration System HC.005 Loss of containment from Fuel Gas System HC.006 Loss of containment from Flare System HC.007 Cargo or Slops Tank Fire/ Explosion HC.008 Hydrocarbon release from Cargo Handling System HC 009 Loss of containment from well blowout NP.010 Loss of containment from Methanol Chemical Injection System NP.011 Engine Room Fire/ Explosion RF.012 Accommodation Fire DO.013 Impact from Dropped Object/ Swinging Load AA.014 Helicopter Crash MA.015 Vessel Collision MA.016 Personnel Transfer Failure SF.017 Structural Failure or Loss of Stability of FPSO OH.018 Confined Space Entry OH.019 Asphyxiation OH.020 Impact to Personnel during FPSO Reconnection to RTM OH.021 Dropped Fast Rescue Craft


Identify systems with safety role in MAH

Apply objective method to

identify those systems which

have a safety role in Major

Accidents

• Bow tie

Identify threats &

assign preventive controls

Control

Assess consequences / impacts & assign recovery controls

Recover


Example Bow tie

Example Bow-Tie: Systems which have a safety role in Major Accidents


List of SECEs with safety role

1) Access, escape and evacuation

routes

2) Ballast and bilge

3) Blowdown, pressure relief and

flare

4) Active Fire Protection (chemical)

5) Flammable gas detection

6) Communications external

7) Drainage (hazardous open)

8) Communications internal

9) Gas systems hydrocarbon

containment

10) Active Fire Protection (water)

11) Electrical fault protection

12) Emergency electrical power supplies

13) Escape lighting

14) Emergency shutdown

15) Risers and pipelines

16) Fire and smoke detection systems

17) Firewater systems

18) Foam systems

19) Portable firefighting equipment


Stage 2: identify SECEs with environmental role

Establish criteria/ thresholds for a major environmental incident

Identify Major Environmental Incident from list of MAHs

(consider scenarios a, b & d)

Identify systems (plant, equipment, IT ) that interact with the hazard or condition

(cause, contribute to or prevent or recover from a major environmental incident)

Evaluate the consequence of system failure and whether consequence constitutes and environmental incident

Confirm SECE has an environmental role

Establish an assurance and verification scheme to manage SECEs

Stage 2 Second review cycle to identify those SECEs that have an environmental role.

Bow-Tie Analysis to confirm SECE with an

environmental role

Confirm scenarios with potential for significant

environmental consequence

Use EIA, Aspects register and OPEP to evaluate significant & lasting

impact

Generate list of SECEs

Performance standards, compliance routines link to maintenance system

Fire, explosion, loss of well control or release of a dangerous substance


MAH with environmental impact

Major Accident Hazards

HC.001 Loss of containment from Production Riser/ Turret System

HC.002 Loss of containment from Crude Separation/ Stabilisation System

HC.005 Loss of containment from Fuel Gas System

HC.007 Cargo or Slops Tank Fire/ Explosion

HC.008 Hydrocarbon release from Cargo Handling System

HC 009 Loss of containment from well blowout

DO.013 Impact from Dropped Object/ Swinging Load

MA.015 Vessel Collision

SF.017 Structural Failure or Loss of Stability of FPSO

Identify MAHs with potential environmental impact • ENVID • Primary focus – loss of

hydrocarbon inventory


Stage 1. Example Bow Tie output

(only those systems which have a safety role in Major Accidents)


Stage 2: Example Bow Tie Output

SECEs with a role in an environmental incident.


List of SECEs with safety and environmental role

Safety Function Environmental Function

BOP and well control

Emergency shutdown

Blowdown, pressure relief and flare

X

Access, escape and evacuation routes

X

Risers and pipeline

Escape lighting

X

Lifeboats

X


Summary

• Simple 2 stage process

• Existing operators – need to review MAHs

& SECEs for environmental implication

using existing information and

transparent procedure.

• New entrants will need to run process

from start, as described.

• Collaborative effort required.

Identify Major Accident events using safety case

Identify system (structure, plant & IT) which can cause, prevent,

detect, control mitigate, rescue or help recover from a major accident

Identify systems for prevention of fire and explosion and emergency

response

Record items identified as SECEs

Establish criteria/ thresholds for a major environmental incident

Identify Major Environmental Incident from list of MAHs

(consider scenarios a, b & d)

Identify systems (plant, equipment, IT ) that interact with the hazard or

condition

Evaluate the consequence of system failure and whether consequence

constitutes and environmental incident

Confirm SECE has an environmental role

Establish an assurance and verification scheme to manage SECEs SECE (safety)

SECE (Environment)

HAZID


Where do we go from here / what can LR offer ?

Focus of SCR 2015

• to reduce the risks from major accident hazards to the health and safety of the workforce

• to increase the protection of the environment

Specifically:

• Regulations require confirmation that the likelihood of a major environmental incident has been identified and its environmental consequence assessed.

Reg 9 • establish a verification scheme for ensuring that the SECEs will be suitable;

and where provided remain in good repair and condition. • produce a written record of the safety and environmental – critical

elements and specified plant

Reg 8 Schedule 3 • SEMS and integration of environmental impact into major accident risk assessments in the safety case.


Where do we go from here / what can LR offer ?

Specifically, we can help you with:

1. Identification of SECE (safety and environmental function)

2. Quantify consequences (both safety and environment impact)

3. Advice regulatory compliance strategies

4. Establish performance standards

• functionality – what is SECE required to do?

• availability – for what proportion of time will the SECE be capable of performing

• reliability – how likely is the SECE to perform on demand

• survivability – does the SECE have a role to perform post event

• interactions – do other systems need to be functional for the SECE to operate

5. Assurance in the management of MAH and SECE (e.g. audits, SEMS processes, procedures and policies)

6. Develop verification scheme

Lloyd’s Register and variants of it are trading names of Lloyd’s Register Group Limited, its subsidiaries and affiliates. Copyright © Lloyd’s Register Consulting. 2013. A member of the Lloyd’s Register group.

Working together for a safer world

Ian Thomas Department Manager Aberdeen T + 44 1224 267 485 / Mobile +44 7785 515 403 E [email protected] Lloyd’s Register Consulting www.lr.org/consulting

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Strategic approach to managing safety and environmental critical elements (SECEs)

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