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This paper identifies key areas of concern regarding the use of deferral as a maintenance management tool. As the national regulator for offshore petroleum operations and greenhouse gas storage activities, National Offshore Petroleum Safety and Environmental Management Authority is uniquely positioned to observe the various processes and tools applied by industry in the management of maintenance for offshore facilities, including impacts on safety and the environment, while acknowledging the need for business sustainability. This Extended Abstract provides a regulator’s perspective on the use of ‘maintenance deferral’ by industry as a tool for balancing competing priorities, while ensuring the risks to people and the environment are reduced to a level that is as low as reasonably practicable. It highlights the pitfalls of maintenance deferral that may negatively influence safety and environmental performance over the life of a facility (from construction through to decommissioning) as well as on the business’ bottom line. Learnings identified from non-compliances, improvement recommendations and incidents to promote efficient and effective learning are shared to further enhance existing good practices across the industry.

The acceleration of decommissioning activities in recent times has expedited the need to decommission responsibly and sustainably. Decommissioning activities are increasingly under public scrutiny, yet in many regions there remains a lack of legislation, regulatory guidance, and practical experience in implementing decommissioning activities. In general, the decommissioning process begins with the assessment stage, followed by planning and management, and lastly the actual decommissioning execution. The best practice approach for responsible decommissioning is to conduct a best practicable environmental option (BPEO) study, which is also known as a comparative assessment and/or decommissioning options assessment. The BPEO will identify the most beneficial or least damaging option to be selected for each decommissioning project by accounting for all relevant influencing aspects such as technical, environmental and social impacts, costs, stakeholder opinions, legal compliance as well as health and safety. Such documentation is important to demonstrate that potential impacts arising from decommissioning activities have either been removed or are reduced to as low as reasonably practicable (ALARP). The best decommissioning option will vary depending on local aspects such as environmental baseline conditions, key stakeholders, waste management and disposal facilities, available technologies and the viability of all options considered including reuse (e.g. rigs to reef). This paper outlines recommended approaches for successful decommissioning planning, highlighting key environmental considerations and other important influencing factors. The aim is to demonstrate the importance of holistic thinking for the development of decommissioning strategies to establish a robust decommissioning plan and successful execution.

Two key facilities for the INPEX-operated Ichthys LNG project; the central processing facility (CPF) and floating production, storage and offloading (FPSO), were constructed in South Korean ports and towed to offshore Australian waters. To meet regulatory requirements for their importation, and mitigate potential invasive marine species (IMS) introduction, species-specific biofouling risk assessments were completed, and a series of management measures implemented. Risk assessments quantified the theoretical likelihood of the facilities introducing IMS via biofouling. The assessments considered (but were not limited to) the type of antifouling coating (AFC), time alongside, niche areas, and likelihood of IMS surviving in offshore waters at the Ichthys Field if translocated. The two facilities had different AFCs on their submerged hulls (CPF: biocidal, FPSO: non-biocidal). The theoretical risk of introducing IMS to Australian waters was considered ‘uncertain’, requiring completion of an extensive pre-mobilisation cleaning program in-water (CPF >600 dive hours and FPSO 2381 dive hours). The FPSO was cleaned twice due to a delay and recolonisation on the non-biocidal AFC. To determine the most efficient cleaning methods, various in-water cleaning technologies were trialled. Due to the size and complexity of the facilities, biofouling inspectors were deployed throughout the operation to increase confidence in the outcomes. After the arrival of the facilities at the Ichthys Field, dedicated underwater surveys were conducted to assess biofouling communities and collect specimens for molecular analysis, using a specially designed sampling tool. The associated outcomes demonstrated that the risk was acceptable and had been reduced to as low as reasonably practicable, validating the novel approach taken.

Esso Australia Resources Pty Ltd and BHP Petroleum (Bass Strait) Pty Ltd own numerous offshore facilities, which have been operated by Esso Australia Pty Ltd (EAPL) for over 40 years. With respect to escape, evacuation and rescue (EER), the long standing philosophy for these facilities has been to muster at the external assembly areas (EAA) near the evacuation lifeboat stations, to allow for swift evacuation when the need is apparent. This philosophy has underpinned the design of these offshore assets to date. For new-build offshore facilities, typical EER philosophies include the provision of an enclosed temporary refuge (TR), specifically to maintain a safe environment for personnel (in the event of an emergency) such that they can muster before evacuation, or remain on the facility until the event is brought under control. TRs typically provide protection to personnel from hazards that the EAA may not (i.e. smoke), but may increase the duration of a potential evacuation if they are not located within close proximity to evacuation stations. This paper considers the potential changes in risk presented by the two evacuation philosophies, and the potential implications of changing from one philosophy to another on an existing facility. The analysis expands to facility operational and design considerations. This paper also describes a methodology to leverage existing quantitative risk assessments to assess (a) how the risk profile to personnel may change depending on the EER philosophy; (b) how the implementation of additional risk controls will impact risk; and (c) how the results of the assessment can be used to establish an ‘as low as is reasonably practicable’ (ALARP) position.

A key challenge of the environmental regulatory framework for offshore petroleum activities in Australia is the requirement to demonstrate acceptability, with the legislation placing the onus on petroleum titleholders to demonstrate that the impacts and risks posed by an activity will be of an acceptable level and reduced to as low as reasonably practicable. This paper presents a case study on the assessment of noise impacts to fishes for the Bethany 3D Marine Seismic Survey, which was acquired by Santos Ltd in mid-2018. The survey area was encompassed entirely by the Oceanic Shoals Marine Park, and also overlapped a significant proportion of the Timor Reef Fishery, a regionally important demersal scalefish fishery. The survey area overlapped a key ecological feature and a range of geomorphic features characterised by benthic habitats supporting demersal and benthic fish communities, including site-attached species. On this basis, the evaluation of impacts and risks required a multi-faceted approach, with seven key elements: (1) acoustic modelling; (2) application of sound exposure guidelines; (3) a quantitative risk assessment (benthic habitat predictive modelling and spatial analysis of site-attached fish assemblages); (4) the definition of an acceptable level of impact; (5) a sound source verification process; (6) engagement with key stakeholders; and (7) an independent, expert peer review process. The outcomes of each of these steps were incorporated into the environment plan, and enabled the titleholder to demonstrate that, with adopted control measures in place, environmental impacts and risks from the seismic survey could be managed to an acceptable level.

As the engineering design process for a major development project advances from concept through to ready for start up, many key decisions are made and controls formulated that ultimately influence environmental, social (and safety) outcomes. These decisions are often made based on sound technical grounds with key decision logs, hazard identification or hazard and operability studies or similar used to record the process, but with limited recognition of environmental outcomes. Many of the onshore and offshore regulations in Australia (most notably, the Offshore Petroleum and Greenhouse Gas (Environment) Regulations 2009) require environmental risks and impacts to be reduced to a level that is as low as reasonably practicable (ALARP). Additionally, justifiable assessment of controls and decisions are presented in the environment plans (EP) that are typically prepared later on in the design process. Challenges can often arise when geographically disparate design contractors lack ALARP assessment processes to evaluate decisions and controls from an environmental perspective and record outcomes for future use in regulatory documentation. This can be particularly pronounced for operations EPs. Janine shares her practical experience in environmental integration in engineering design to showcase methods that tangibly demonstrate robust decision-making, inclusive of delivering environmental outcomes, to regulators.

Lurking on the balance sheet of all offshore operators is a line item typically referred to as ‘abandonment costs’. Such costs are usually estimates made using assumptions of total removal and can run into the tens or hundreds of millions of dollars. In the next 25 years, it is estimated that 100 offshore oil-production installations will need to be decommissioned in Australia, with an anticipated cost in excess of AU$1.2 billion. Most jurisdictions around the world ostensibly require total removal of all facilities post-production. In Australia and elsewhere, including the Gulf of Mexico and North Sea, there is an opportunity to propose deviations from total removal if there are good grounds for doing otherwise. The main alternative to removal, that is, in situ decommissioning, can offer many advantages including reduced cost, environmental impact and worker exposure to safety hazards. Furthermore, the application of a stage-gate project approach – more traditionally used in oil and gas development stages (appraise, select, define, execute) – enables the effective integration of the inputs from the wide variety of stakeholders involved in a decommissioning project, as well as efficiently handling the potentially large volume of information and analysis that is involved. Drawing on recent project experience, this paper describes the practical approaches needed to ensure a robust assessment and determination of ALARP.

A significant risk with any oil and gas production facility is equipment exposure to low temperature fluids, which can lead to brittle fracture, loss of hydrocarbon containment and ignition, with potential consequences including multiple fatalities, major asset damage, production deferment and profound operator reputational harm. Due to the nature of the initiating low-temperature events, which often occur as a result of a sequence of control system, hardware or operational failures, these issues are not always adequately addressed in facility design and operation, which can lead to unacceptable and potentially unacknowledged asset risk exposure. This is especially true in a cost-constrained environment where economic and schedule pressures can drive a leaner approach whereby, for example, traditional design margins are challenged. Drawing on S2V Consulting’s extensive expertise in this area, this technical paper outlines examples of typical low-temperature exposure mechanisms and key facility risk areas. It highlights why there can be failures in mitigating these risks, both during initial facility design and throughout subsequent operating phase evolution, discusses analytical methods or tools and highlights potential mitigation measures. A structured evaluation process developed by S2V Consulting is presented that can be adopted to effectively safeguard facilities by ensuring these risks are identified, screened, prioritised and managed to ALARP (as low as reasonably practicable). Finally, case studies are presented to provide context to the issue and demonstrate the effective application of the evaluation process to several current Australian production facilities.

Demonstration that risks are reduced to as low as reasonably practicable (ALARP) is a fundamental element of safety and environment regulation in the Australian oil and gas industry. The principle is well established, and offers operators relative flexibility in designing and managing their operations when compared to the more prescriptive regime adopted in other countries, such as the US. The approach, however, to building the ALARP case invariably differs between safety, environmental, and technical disciplines within oil and gas operators, leading to conflicting outcomes and sub-optimal solutions, which in turn can hamper production output and efficiency. A recent change in offshore regulations requires operators to focus on reducing overall environmental impacts from produced water through the ALARP principle, rather than by a prescribed limit. Through options screening, detailed technical studies, and consideration of environment and health and safety trade-offs, a robust ALARP position can be achieved, which yields increased production and efficiency, and reduced environmental impact, health and safety risk and associated cost. Drawing on recent project case studies with offshore oil and gas operators in Australia, the authors present best practices in the development of integrated ALARP cases for activities including produced water treatment and decommissioning.

In 2001, Esso submitted 18 different Bass Strait Facility Safety Cases as part of their five year revision cycle, and obtained regulatory acceptance for each of them. These revised safety cases incorporated the accumulated learning from our many previous offshore safety case submissions, the 1998 Longford accident and our work with the WorkSafe Victoria Major Hazards Division. A number of significant challenges were met and overcome. This paper discusses our experiences and describes the processes we used to successfully develop useful, easy to use living safety cases for our offshore workforce.Although our priority was to demonstrate that we knew our facilities, had identified hazards, assessed the risks associated with those hazards and had control measures in place to reduce those risks to as low as reasonably practicable, we also wanted to bring about behavioural change. This paper will explain how our safety case revision processes were used to successfully change workforce behaviours with consequent changes to collective attitudes and values across the organisation.Extensive and highly effective employee involvement was integral to all stages of the safety case planning and development process. The paper examines how a skilled team comprising a workforce-elected Health and Safety Representative, an Offshore Installation Manager and specialist safety professionals collaborated to deliver a true program of workforce involvement and buy-in that in turn delivered the behavioural changes necessary for a true safety case culture to flourish.Esso’s approach of developing a safety case as a shopfloor friendly tool highlighting the linkages between routinely used safety management system controls and the major accident event risks present at the workplace has delivered significant benefit in developing a risk averse health and safety culture. A comprehensive ongoing learning program designed to give the workforce the knowledge, skills and confidence needed to use the safety case to maximum advantage, has been developed as a key component of our safety case program. This paper explores the successful planning, development and implementation of this innovative learning program that has been widely recognised by regulators and industry.

As a proactive step in the management of Health and Safety, WAPET as operator on behalf of its Joint Venture Participants, considered it good practice to develop a Safety Case for the onshore component of the Thevenard Island facilities and operations along with the legislated offshore requirement. The development of the Safety Case utilised a process which incorporated qualitative assessment of risk, quantification of key risks and assurance that risks were as low as reasonably practicable. For this existing facility, the process clarified the quality of the existing hazard controls and provided an opportunity to make significant improvements.The process used ensured a high degree of employee and Regulator involvement throughout the Facility Description, Safety Management System and Formal Safety Assessment components of the Safety Case. This has achieved a high degree of awareness among the operations staff of risk management techniques. These techniques are now being applied routinely in the management of the operation.

Following major incidents and a worldwide trend to a more structured approach to managing offshore safety, the Australian Government has regulated for the preparation of Safety Cases for all new offshore projects which commence design work after 1 July 1992. The Safety Case is required to demonstrate that safety management systems are adequate to ensure design, construction and operation of the installation are safe, that potential major hazards have been identified and appropriate controls are provided to ensure that risks are as low as reasonably practicable, and that adequate provision has been made for safe evacuation, escape and rescue. The safety case should be prepared using a balanced approach that results in a practical and value-added case.This paper summarises the approach adopted by Esso Australia in the preparation of safety cases for two new Bass Strait developments. It specifically covers the development of detailed internal guidelines for use in preparing safety cases, the safety case structure, content and emphasis, and includes examples to illustrate the key aspects of the Esso Australia Safety Case approach. The methodology described provides an effective means of achieving the objectives of a safety case.