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PROVIDENCE RESOURCES PLC

KISH BANK EXPLORATION WELL

OIL SPILL CONTINGENCY PLAN

Client Providence

Project Title Kish Bank Exploration Well

Document Title Oil Spill Contingency Plan

Document No. MGE0282RP005

This Document Comprises

DCS TOC Text List of Tables List of Figures No. of Appendices

1 1 60 1 1 0

Rev. Status Author(s) Reviewed By Approved By Office of Origin Issue Date

A01 Client Approval

Galway 12th Sept 2011

F01 Final

Galway 12th Oct 2011

F02 Final

Galway 12th Nov 2011

Confidentiality statement:

The information disclosed in this proposal should be treated as being strictly private and confidential and you are requested to take all reasonable precautions to maintain its status as such. You are requested to use and apply the information solely for the purpose of evaluating this proposal and are asked not at any time to disclose or otherwise make available the information to any third party except for those officers, employees and professional advisers who

are required by you in the course of such evaluation to receive and consider the information and who agree to be bound by these non-disclosure terms

Kish Bank Exploration Well OSCP Rev 00

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Document Control Document Title KISH BANK EXPLORATION WELL OIL SPILL CONTINGENCY PLAN

Document Ref No. TBA

Document Keeper TBA

Controlled Copy No. TBA

Controlled Copy Holders Copy Number

Company Position

1 Petroleum Affairs Division (PAD)

TBA

2 TBA

3 Irish Coastguard (IRCG)

TBA

4 TBA

5 Department of Defence, Executive Branch and Naval Services TBA

6 Health and Safety Authority (HSA)

TBA

7 TBA

8 Providence Resources Plc Operations Manager

9 Technical Director

10 Drilling Contractor (TBA) Rig Manager

11 Environmental Manager

12 ERC Room

13 Drilling Rig (TBA) OIM

14 Providence Offshore Drilling Supervisor

15 Standby Vessel Vessel Master

16 OSR Operations Room

17 Well Management Company (TBA) Operations Manager

18 Well Team Leader


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Document Revisions Record REVISION PAGES

Date Section No./Description of Changes Pages Removed Pages Inserted

19h Sept 2011

Generic Copy Issued to Marine Licence Vetting Committee 0 0


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ABBREVIATIONS API American Petroleum Institute

BOP Blow Out Preventer

DCENR Department of Communications, Energy and Natural Resources

DoT Department of Transport

ECC Emergency Control Centre

ERO Emergency Response Organisation

ERR Emergency Response Room

ERT Emergency Response Team

GOR Gas:Oil Ratio

HSA Health and Safety Authority

HSEQ MS Health, Safety, Environmental and Quality Management System

IAA Irish Aviation Authority

ICS Irish Continental Shelf

IOE Institute for Offshore Engineering

IOOA Irish Offshore Operators Association

IRCG Irish Coast Guard

ITOPF International Tanker Owners Pollution Federation

MODU Mobile Offshore Drilling Unit

MRCC Maritime Rescue Coordination Centre

MSD Maritime Safety Directorate

NCP National Contingency Plan

NSEP A/S Norske Shell Exploration and Production

OGUK Oil and Gas UK (formally UKOOA)

OIM Offshore Installation Manager

ORT Oil Spill Response Team

OPEP Oil Pollution Emergency Plan

OSR Oil Spill Response

PAD Petroleum Affairs Division (DCENR)

PCV Pollution Control Vessel

SBV Stand-by Vessel

SEPIL Shell E & P Ireland Limited

SRC Shoreline Response Centre

U.K United Kingdom

UKCS United Kingdom Continental Shelf

UKDCC UK Dispatching Coordination Centre

UKOOA United Kingdom Offshore Operators Association (see OGUK)

VHF Very High Frequency

WBM Water Based Drilling Mud


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Table of Contents

1 Introduction .............................................................................................................................. 1

1.1 Scope of Plan .................................................................................................................. 1

1.2 Proposed Kish Bank Exploration Well – Overview of Operations ..................................... 1

1.3 Dublin Bay ....................................................................................................................... 3

1.4 Previous Incidents in Dublin Bay ..................................................................................... 3

1.5 HSE&Q Policy .................................................................................................................. 5

1.6 Roles and Responsibilities of Interested Parties .............................................................. 6

1.7 Operational Responsibilities ............................................................................................ 6

1.8 Government Responsibilities ........................................................................................... 6

1.9 National Plan and Other Interfaces .................................................................................. 8

1.10 Legislation ....................................................................................................................... 8

1.11 Document Control Procedures ......................................................................................... 9

2 Existing Environment ............................................................................................................. 10

3 Risk Assessment ................................................................................................................... 13

3.1 Introduction .................................................................................................................... 13

3.2 Likelihood of Spill Occurring .......................................................................................... 13

3.3 Potential Spill Scenarios ................................................................................................ 14

3.4 Fate of Spilt Oil .............................................................................................................. 16

3.5 Effect of Spilt Oil and Environmental Risk ...................................................................... 20

3.6 Spill Prevention and Mitigation ....................................................................................... 23

4 Oil Spill Response Strategy ................................................................................................... 24

4.1 Tiered Response............................................................................................................ 24

4.2 Oil Spill Quantification.................................................................................................... 30

4.3 Manual Calculation of Slick Movement .......................................................................... 32

4.4 Oil Spill Response Options ............................................................................................ 35

4.5 Response Strategy Decision Tree ................................................................................. 39

5 Response Actions .................................................................................................................. 40

5.1 Structure of the Response Organisation ........................................................................ 40

5.2 Offshore Response Team Actions ................................................................................. 42

5.3 Onshore Response Team Actions ................................................................................. 43

6 Reporting Requirements ........................................................................................................ 47

7 Contact Telephone and Fax Numbers .................................................................................... 49

8 Checklists and Pro Forma Templates .................................................................................... 51

8.1 Oil Spill Assessment Checklist ....................................................................................... 51

8.2 Incident Briefing Checklist ............................................................................................. 52

8.3 Personal Log Checklist .................................................................................................. 53

8.4 Oil Sampling Checklist ................................................................................................... 54

8.5 Oil Spill Report Form ..................................................................................................... 55


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8.6 Information Required by IRCG Prior to Approval to Spray Chemical Dispersant ........... 56

8.7 IRCG Notification Following Use of Dispersant .............................................................. 57

8.8 Oil Spill Log ................................................................................................................... 58

8.9 Aerial Surveillance Observers Log ................................................................................. 59

9 References............................................................................................................................. 61


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1 Introduction

1.1 Scope of Plan

This document is the Oil Spill Contingency Plan (OSCP) for the Providence Resources PLC (hereafter referred to as ‘Providence’) Kish Bank exploration well, located in Block 33/21 off the east coast of Ireland.

The purpose of this OSCP is to provide guidance on actions and reporting requirements for personnel and contractors associated with Providence in the event of an oil spill originating from operations at the Kish Bank exploration well. Where a spillage is part of a wider emergency, such as fire or explosion, reference should also be made to Providence’s Emergency Response Plan.

The Plan is developed and finalised following detailed modelling and discussion with the Irish Coast Guard and other relevant agencies. The likely nature of the reserve, detail of the drilling programme, and the specifics of the vessels, rigs etc are all required to produce the OSCP. This information will be available following the Site and Seismic Survey in 2012. This document is intended to provide information on the operation and responses and indicate the requirements and content of the Oil Spill Contingency Plan, which is issued to operators, relevant authorities, managers and response teams prior to operations commencing.

Where specific information is not available, this document discusses the methods employed or provides examples from previous Providence experience in Ireland. The OSCP follows the recommended format proposed in the Oil Pollution Preparedness, Response and Co-operation Convention 1992.

1.2 Proposed Kish Bank Exploration Well – Overview of Operations

Providence Resources PLC has been active in the exploration for hydrocarbons offshore and onshore since 1997 however its predecessor companies have been involved in the industry since 1981. The company has an experienced geological, geophysical, engineering and commercial team screening prospects and participating in both operator and non-operator roles. Since 2000 Providence Resources PLC has successfully operated 6 offshore Ireland wells and associated site surveys. These wells, all located in the Celtic Sea Basin, were in a water depth of approximately 100m.

Providence is presently operating a further well on the Barryroe Licence in the Celtic Sea.

P.R. Singleton Limited, a wholly owned subsidiary of Providence Resources PLC has also operated the drilling of three extended reach horizontal production wells (9,000 10,100 & 13,000ft MD) on the Singleton Oil Field since March 2009. These wells were successfully drilled in the environmentally sensitive South Downs National Park, UK.

Providence Resources has successfully operated the acquisition of both 2D and 3D seismic survey datasets in the Irish offshore. Between 1997 and the most recent Barryroe 3D acquired in June 2011, Providence operated the acquisition of four 2D surveys and three 3D surveys in the Celtic Sea in water depths of 80m to 110m. Between 2006 and 2011 a Long-Offset 2D survey and two 3D surveys were acquired in the Porcupine basin, in water depths ranging from 300m to 1500m.

Providence Resources PLC is a member of OPOL and UKOOG and an experienced oil and gas operator.

Providence is planning to drill the Kish Bank exploration well in 2012 after conducting a site survey in the early part of the year. The Kish Bank exploration well will be located in Block 33/21, approximately 6 kilometres from nearest landfall (Figure 1.1).


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Figure 1.1: Location of Kish Bank Exploration Well


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The Kish Bank Exploration well will be named by the PAD after the well is spudded. Further details on the drilling programme and characteristics of the Kish Bank exploration well are provided in Table 1.1. These are provisional and will be conformed after a site and seismic survey is undertaken in 2012.

Table 1.1: Kish Bank Exploration Well Details

Feature Characteristic

Well Surface Location X:302129; Y:5 904 406 (provisional to be confirmed by site survey)

Operator Providence Resources PLC

Block Number 33/21

Nearest mainland Dalkey, Co. Dublin, Ireland

Water depth 85 ft

Reservoir Depth 11,500 ft

Anticipated Reservoir Hydrocarbons TBA

Standby Vessel TBA

Drilling Rig TBA

Proposed Spud Date TBA

Drilling Duration Dry Hole: 30 days; Success Case: 60 days

Well test DST (TBC)

To date there have been four previous exploratory wells drilled in this area (Amoco 33/22-1(1977), Shell 33/21-1(1979), Charterhouse 33/17-1(1986), and Enterprise 33/17-2 (1997), without incident. In addition, between 2009 and 2010 the Fugro Synergy carried out drilling activities related to a coal degasification project in the Kish Bank area and in 2010 the Aran 250 and Excalibur drill rigs carried out geological borehole activities on the Kish Bank in relation to the proposed windfarm development. Providence has a history of operating in Ireland to the highest standards with no incidents reported.

1.3 Dublin Bay Dublin Bay (Irish: Cuan Bhaile Átha Cliath) is a C-shaped inlet of the Irish Sea on the east coast of Ireland. The bay is about 10 kilometres wide along its north-south base, and 7 km in length to its apex at the centre of the city of Dublin; stretching from Howth Head in the north to Dalkey Point in the south. Dublin Port centred in Dublin Bay is a significant infrastructure site (205 hectares / 507 acres), and Irelands biggest seaport. Approximately two thirds of Ireland’s port traffic goes through the port, and it is estimated that approximately 90% of all items and consumables for the city of Dublin are supplied through the facilities. Within the main port enclave, there is a power generating station (gas-fired), several oil terminals and number of businesses, such as car, fuel, building materials and flour importation and handling sites and the ferry terminals.

1.4 Previous Incidents in Dublin Bay In October 1996 an oil spill was detected in Dublin Bay from the area around Burford Bank. The Oil Spill Response Plan for Dublin, developed after the sinking of the MV Kilkenny following a collision with the MV Hasselwerder on the 21st November 1991. Since this date there have been two other recorded incidents in 2001 and 2009 related to land based accidental discharges.


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In relation to the 1996 incident the response plan functioned as follows. The Irish Marine Emergency Service of the Department of Communications Natural Resources and Marine was notified of a possible oil pollution incident near the Burford Bank in Dublin Bay. IMES immediately activated the oil spill response contingency plan for Dublin. There is an emergency plan for dealing with oil pollution incidents which is co-ordinated by IMES and involves the relevant local councils and authorities in the Dublin Bay area. All relevant agencies were advised of the report. The Air Corps was requested to deploy a helicopter to survey the area. Following confirmation that an oil spillage had occurred, all relevant local and harbour authorities activated their contingency plans on instruction from the Department and reported on the extent of the pollution in their areas of responsibility. Because no report of accidental oil discharge, or other accident (vessel collision etc) had been received it was assumed at the time this pollution incident resulted from an illegal discharge which had occurred during the night of 20-21 October 1996. A marine notice was issued requesting all shipping to report any sighting of oil pollution. Dublin Air Traffic Control was requested to have all passing aircraft monitor the area. The Department instigated an emergency meeting of all response agencies and interested parties which included Dublin Corporation, Dún Laoghaire Rathdown County Council, the harbour authorities, the Irish Wildbird Conservancy and the Irish Society for the Prevention of Cruelty to Animals. Aerial surveillance missions revealed a number of pollution spots at sea and on the coastline from Howth to Killiney and only one oily patch at sea, south of Bray Head. Much of the oil appeared to have dispersed. Inspections on the shoreline were carried out by Dún Laoghaire Rathdown County Council revealed minor oil pollution at Coliemore Harbour, Bullock Harbour, Dún Laoghaire Coal Harbour and Killiney Beach. In Dún Laoghaire, the western corner of the coal harbour was boomed and the contaminated material removed. Notices were placed at the beaches at Vico, Killiney, Corbawn and Quinn's Point advising the public of the possibility of oil contamination. Up to 600 oiled birds were recovered for treatment at the UCD facilities. This aspect of the response was co-ordinated by the Wildlife Service of the Department of Arts, Culture and the Gaeltacht. Dublin Port and Docks Board reported no trace of oil in Dublin Port. Onshore inspections carried out by the local authorities reveal that no further oil has come ashore and that very little residue is left in the affected areas. The affected areas are being cleared by natural process and no intervention has been required. Samples of the oil pollution were sent to Fisheries Research Centre of the Marine Institute for prosecution purposes. The Department and the local authorities continued to monitor the situation on the beaches and at sea.

This highlights the emergency response plan. In the case of Providence’s operations the information from the Drilling Contractor will be integrated with a specific major incident plan once the details and timing have been agreed. This will be prepared as part of the consultation with the Department, and will form Section 5 of this document which will be distributed to all relevant personnel. For the purpose of this information document supporting the foreshore application, previous examples and information on the approach are included.


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1.5 HSE&Q Policy


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1.6 Roles and Responsibilities of Interested Parties

If an oil spill was to occur during operations, the fundamental legal responsibility for clean-up would rest with Providence as the Operator. Government authorities would, in most cases, monitor the clean-up activities while reserving the right to intervene actively if the operations were not being appropriately carried out, or if it became apparent that the problem was beyond Providence’s capability to resolve. The responsibilities of relevant government organisations are provided in Section 1.8.

1.7 Operational Responsibilities

Providence recognises that as the Operator and concession owner it has operational and financial responsibility for cleaning up oil spilt during the course of its operations.

In compliance with Irish and International legislation, Providence is responsible for ensuring appropriate government notification, offshore clean-up and disposal of recovered oil following all pollution incidents.

Providence is also responsible for developing and maintaining the OSCP in accordance with the Sea Pollution (Amendment) Act 1999.

1.8 Government Responsibilities

A number of Irish government departments have responsibilities for, and are involved in the process of oil spill contingency planning and response to oil spills as outlined below. It should be noted that once the site survey has been completed, this OSPC document will be updated and details of the specifics of Dublin Bay will be finalised. In addition, submission of this document is part of the PAD application process and is forwarded to all relevant government bodies. From their review, details such as a master action plan and thresholds of reporting will be finalised.

1.8.1 Department of Transport (DoT)

DoT is the lead organisation responsible for shipping and general navigational matters, the carriage of dangerous goods by sea, marine communications, search and rescue, pollution control, salvage, and protection of the marine environment.

A key body within the DoT is the Irish Coastguard (IRCG), whose main responsibilities include:

Search and Rescue - providing assistance to persons who are, or appear to be, in distress within Ireland’s internationally assigned search and rescue region, the littoral area, rivers, lakes, waterways, mountains, caves and offshore islands.

Organise and prepare the response to oil spills and other hazardous substances within the Irish Pollution Responsibility Zone1;

Provide an effective response to marine casualty incidents;

Monitors/intervene in marine salvage operations; and

Provide and maintain a 24 hour marine pollution notification centre through the Marine Rescue Coordination Centre (MRCC) Dublin, including:

Developing approved pollution response plans in all harbours and ports, oil handling facilities, marine local authorities and offshore installations;

1 Ireland’s Pollution Responsibility Zone covers an area stretching to 200 miles off the west coast and to the median line between Ireland and the UK in the Irish Sea and Celtic Sea. The area covers approximately 200,000 sq km. The zone is a resource of high value in terms of ecological and socio-economic use. It is a very ecologically sensitive area with a wide variety of fauna and flora. It supports an active leisure industry with a large number of blue flag beaches and also commerce including fisheries, marine transport and natural resources.


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Providing and maintaining a national stockpile of pollution equipment; and

Carrying out exercises and tests of national and local pollution response plans on an ongoing basis.

The IRCG represents the public interest in the protection of the environment following a marine incident where there is a threat of pollution.

1.8.2 Department of Communications, Energy and Natural Resources (DCENR)

DCENR is responsible for the management and protection of the Irish maritime natural resources, while ensuring that activities are conducted safely and with due regard to their impact on the environment and other land/sea users.

Petroleum Affairs Division (PAD)

Within the Natural Resources section of DCENR, the Petroleum Affairs Division (PAD) is responsible for the promotion, regulation and monitoring of the exploration and development of oil and gas in onshore and offshore Ireland. This involves the allocation of acreage to exploration companies under various types of licences, agreeing appropriate work programmes and the promotion of acreage, either through open access or by a Licence Round system.

PAD has a wide range of roles and functions in environmental protection including:

Strategic Environmental Assessments (SEA);

Coastal Zone Management; and

Fisheries Management.

1.8.3 Department of Environment, Community and Local Government (DoECLG)

DoECLG have responsibility for emergency planning, and would be involved in the event of onshore impact by oil on or near to the coastline. The local authority would work with the IRCG and Providence in the event of an onshore oil spill clean-up being required. The Department also are responsible for Foreshore Licensing and Permitting for the position drilling operation.

1.8.4 Health and Safety Authority (HSA)

HSA has the responsibility for safety, health and welfare at work and operate under the Safety, Health and Welfare at Work Act 2005. They work in partnership with employers and employees, with the responsibility to ensure that safety and health in the workplace is a key priority for everyone. Although HSA are not directly involved in oil spill procedures per se, they must be notified in the case of an emergency.

1.8.5 Irish Aviation Authority (IAA)

IAA was established as a commercial state-sponsored body and is responsible for the provision of air traffic management service in Irish controlled airspace and the safety regulation of the Irish civil aviation industry (including helicopters).

The IAA safety regulatory service includes:

Aircraft airworthiness certification and registration;

The licensing of personnel and organisations involved in aircraft maintenance;

The licensing of pilots, air traffic controllers and aerodromes; and

The approval and surveillance of air carrier operating standards.


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1.9 National Plan and Other Interfaces

1.9.1 National and Local Plans

The Irish National Contingency Plan (NCP) was developed by the IRCG. It sets out the arrangements for dealing with a spill of oil or other hazardous material in Irish waters. IRCG is the organisation responsible for implementing the NCP.

Within the framework of the NCP, in the event that an oil spill reaches within 1 nautical mile of the shore, the Local Authority has an obligation to manage clean-up. Each Local Authority has prepared an OPEP. The Local Authority may request the attendance of IRCG and arrange the setting up of a Shoreline Response Centre (SRC). If the spill is extensive the clean-up may involve more than one adjacent Local Authority who will then liaise and work together.

The direct involvement of the IRCG in the event of an oil spill from an offshore installation is not automatic, however MRCC Dublin are to be notified in the event of any oil spill. The responsibility for oil spill clean-up rests with the Operator. IRCG will monitor the spill and the response and will only intervene if the clean-up operations are not being carried out to their satisfaction, or if the oil spill clean-up is beyond the capability of the Operator.

1.9.2 Other Plans

This plan interfaces with the following plans, as illustrated below:

1.10 Legislation

Table 1.2 shows the legislation governing oil spill response requirements on the Irish continental shelf.

Table 1.2: Legislation, Regulation and Guidelines Governing Oil Spill Responses on the Irish Continental Shelf

Legislation, Regulations and Guidance Notes

International Convention on Oil Pollution Preparedness, Response and Co-operation 1990 (OPRC Convention)

Ireland is a signatory to this international convention governing oil spill response and has incorporated it into national legislation (see below).

Petroleum and Other Minerals Development Act 1960 (No. 7 of 1960)

Gives the Minister the power to grant licenses, leases and conditions for hydrocarbon exploration and production.

Rules and Procedures for Offshore Petroleum Exploration and Appraisal Operations, issued by the PAD, May 2007.

Requirements for applications and approval relating to petroleum exploration operations. Restricts the use of chemical dispersants in the clean up of oil spills.

Dumping at Sea Act, 1981 (No. 8 of 1981) Restricts the dumping of any material at sea except under licence.

Oil Pollution of the Sea (Civil Liability and Compensation) Act, 1988

Codifies law stemming from the International Convention on Liability for Oil Pollution damage.

Sea Pollution Act, 1991 (No. 27 of 1991) Prohibits the pollution of the sea except under license.

Irish National Contingency Plan

Kish Bank Exploration Well Oil Spill

Contingency Plan

Providence Emergency

Response Plan

Applicable County OSCPs (Regional / Local / Area Plan)

Greater Dublin (DCC, Fingal, South Dublin, Dublin Port etc)


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Legislation, Regulations and Guidance Notes

Safety, Health and Welfare (Offshore Installations) (Emergency Procedures) Regulations, 1991 (SI No. 14 of 1991)

Regulations concerning Emergency Procedures Offshore. An Oil Spill Pollution Contingency Plan must be prepared as part of or separately from the obligatory Emergency Response Manual for offshore installations.

Dumping at Sea Act 1996 Coastal Zone Administration Division responsible for administering permits to ‘dump’ at sea.

Waste Management Act 1996 and Amendment 2003

The management of waste including hazardous waste.

Oil Pollution of the Sea (Amendment) Act, 1998 Amends law on Liability for Oil Pollution.

Sea Pollution (Amendment) Act, 1999 Preparation and submission of oil spill plans and reporting of oil spills.

Oil Pollution of the Sea (Amendment) Act, 2003 Amends law of 1988 and recognises EC Supplementary Fund.

Protection of the Environment Act 2003 Integrated pollution prevention and control. Amends the Environmental Protection Act 1992 and Waste Management Act 1996.

Sea Pollution (Miscellaneous Provisions) Act 2006

Recognises the International convention civil liability for bunker oil pollution and Preparedness, Response and Co-operation to Pollution Incidents by Hazardous and Noxious Substances 2000.

1.11 Document Control Procedures

This OSCP is a controlled document. Circulation and issuing of changes or updates is managed within the Providence document control procedures, which are defined within the Company's Health, Safety, Environmental and Quality Management System (HSEQ MS).

As a minimum, this OSCP will be revised and resubmitted for approval by PAD within a five year period, consistent with the Sea Pollution (Amendment) Act 1999. Where any major change occurs which affects, or could affect, the validity or effectiveness of this plan to a material extent, a new plan, or amendments to the existing plan will be submitted to the PAD within three months of such change becoming known to Providence.


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2 Existing Environment

In this section the environmental resources within the vicinity of Block 33/21 have been identified. The assessment criteria, used to evaluate the environmental sensitivities in this section, are outlined in Table 2.1 below.

Seabirds and fisheries are among the environmental aspects most at risk in the unlikely event of an oil spill. The overall impact of spilt oil on the marine environment will vary seasonally due to variations in species abundance and behaviour.

The exploration well is currently scheduled to be drilled during the second half of 2012 (though may occur in 2013), with the duration of the well operations expected to last a maximum of 60 days. A summary of the key environmental sensitivities within the block/s during the proposed drilling period are as follows (Table 2.2). This will be updated once the drilling period and timetable is confirmed. An environmental impact assessment is included in the Environmental Area Assessment of the Drilling Operations.

Table 2.1: Assessment Criteria

Assessment Criteria based upon the Oil and Gas UK Environmental Assessment Criteria

Major

Change in ecosystem or activity over a wide area leading to medium term (>2years) damage but with a likelihood of recovery within 10 years.

Possible effect on human health. Financial loss to users or public.

Moderate

Change in ecosystem or activity in a localised area for a short time, with good recovery potential. Similar scale of effect to existing variability but may have cumulative implications.

Potential effect on health but unlikely, may cause nuisance to some users.

Minor Change which is within scope of existing variability but can be monitored and/or noticed.

May affect behaviour but not a nuisance to users or public.

Negligible Changes which are unlikely to be noticed or measurable against background activities.

Negligible effects in terms of health or standard of living.

Due to the seasonality of the receiving environment the sensitivities cannot be confirmed until the drilling programme is finalised. As a result, all potential sensitivites have been included in Table 2.2


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Table 2.2: Summary of Environmental Sensitivities to an Oil Spill in the Vicinity of Block 33/21

Feature Activity Impact of Small Spill

Impact of Moderate Spill

Impact of Large Spill

Impact of Response Tactics

Plankton production

Plankton productivity is dependant on seasonality and will be confirmed when the drilling is scheduled.

Minor Minor Moderate Mechanical removal of the oil will reduce the impact.

Chemical dispersion of the oil will increase the impact.

Natural dispersion of the oil will have little impact

Discuss possible strategy with IRCG and the conservation bodies. Use of dispersants is not Irish policy; its use would generally only be allowed for safety reasons.

Fish (Figure 2.1)

Fish spawning and nursery areas: (based on drilling in late 2012)

Species Jun Jul Aug Sep Oct Nov Dec

Cod

Mackerel

Haddock

Horse Mackerel

Whiting N N N N N N

Peak Spawning Spawning N Nursery

Minor Moderate Moderate

Commercial Fisheries

In the area of the well, some fisheries are operating. Commercial fisheries for cod haddock etc do occur in the area, but not at the well site. The only potential fisheries that could be affected are the static gear fisheries for lobster, crab and the whelk fishery

Minor Minor / Moderate

Moderate / Major

Offshore Seabirds

Jun Jul Aug Sep Oct Nov Dec

Northern Fulmar

European Storm Petrel

Manx Shearwater

Sooty Shearwater

Cory’s Shearwater

Northern


Moderate / Major

Mechanical removal or chemical dispersion of the oil will reduce the impact.

Allowing natural dispersion of the oil will increase the impact if sensitive features are present and in the path of the oil. To find this out it would be necessary to survey the sea surface from a vessel or aircraft, to identify them and to predict the movement of the oil by using an oil spill model and weather forecast.

Discuss possible strategy with IRCG and the conservation bodies. Use of dispersants is not Irish policy; its use would generally only be allowed for


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Gannet

Great Skua

Pomarine Skua

Arctic Skua

Long Tailed Skua

Herring Gull

Lesser Black-Backed Gull

Great Black-Backed Gull

Kittiwake

Common Guillemot

Black Guillemot

Razorbill

Atlantic Puffin

KEY Presence Absence *

safety reasons.

Cetaceans The EEA indicates the following species may be present in the area at any time of the year


Moderate / Major


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Common Dolphin, Bottle-nosed Dolphin, Risso’s dolphin, Harbour Porpoise

Killer whale, Minke Whale, Humpback whale, Fin whale, Common Seal, and Grey Seal

Protected Sites (Figure 2.2)

Figure 2.2 indicates the nearest protected areas. The nearest Natural 2000 site is 6km away from the well. The nearest protected area is 8km away and the nearest Natura 2000 site with marine features is 8km away

Minor Moderate Moderate

Oil and Gas Operations

No activity in Irish waters expected in this area during the well drilling operations

Negligible Negligible Negligible Operation will be co-ordinated with any other relevant organisations through the PAD.

Shipping Well is outside major shipping lanes. Potential spill could occur in shipping areas, causing exclusions during dispersion

Minor Moderate Moderate Mechanical removal of the oil will reduce the impact.

Chemical dispersion of the oil will reduce the impact.

Natural dispersion of the oil will reduce the impact

Discuss possible strategy with IRCG and the conservation bodies. Use of dispersants is not Irish policy; its use would generally only be allowed for safety reasons.


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Figure 2.1: Fish Spawning and Nursery Areas in the Vicinity of Kish Bank Exploration Well ( from Coul et al, 2000 and IOSEA4 (in press))

Cod Haddock

Horse mackerel Mackerel

Whiting


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Figure 2.2: Protected Areas and Coastal Sensitivities


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3 Risk Assessment

3.1 Introduction

This section identifies the type and size of oil spill that the Kish Bank oil spill response arrangements may have to cope with. It looks at the generic likelihood of spills that could occur from typical operations, gives an overview of the potential ‘operational’ and ‘worst case’ scenarios, the fate of the oils involved and the effect of spills on the environment.

The severity of effects from an oil spill is dependant on a very wide range of factors including volume of oil spilled, physical and chemical nature of the oil, location of spill and proximity of shoreline or other sensitivities, weather and sea state conditions during and following the spill, hydrographic conditions, time of year and time of day. Given this variety of factors accurate predictions of effects before a spill are difficult to make. However in spill contingency planning, consideration of environmental resources potentially affected by a spill in conjunction with the results of trajectory modelling allows the identification of likely response options and resource needs. Rapid access to information on the environmental conditions and features is essential in actual or simulated oil spill response.

3.2 Likelihood of Spill Occurring

The likelihood of an oil spill from a particular operation can be estimated from analysis of historic spills under similar conditions. One of the best sources of long term data on spills is a report published by Oil and Gas UK (formerly UKOOA): ‘Report on the Analysis of DTI UKCS Oil Spill Data for the period 1975-2005.’ The report uses historical DECC (formerly DTI) oil spill data (1975-1997), DECC PON1 spreadsheets (1998-2005) and field information from the DECC Brown Book, DECC website and OPL Field Development Guide. Although the Kish Bank exploration well is not located on the UKCS, conditions are similar; therefore the data gives a good indication of potential spill scenarios from the proposed drilling operations.

The likelihood of an oil spill occurring in the UKCS increased from 1975 to 2005, along with oil and gas activity. However, normalised against the number of fields, spill frequency is seen to level off to just under 1.5 spills per field (refer to Figure 3.1) though the average volumes spilled have dramatically reduced.

Figure 3.1: Number of Spills and Spill Amounts Normalised by the Number of Fields in Production (UKOOA, 2006)

Figure 3.1 also indicates that the quantity of oil spilled per field has decreased greatly during the 1990s. The Oil and Gas UK (OGUK) report (UKOOA, 2006) suggests this may be due to improved environmental management. The decrease in spill volume in recent years is also highlighted by Figure 3.2, which shows that the distribution of spill sizes has shifted toward smaller volumes, with the most common spill size being between 0.1 tonnes and 1 tonne. There are also a significant number of spills between 0.0001 tonnes


MGE0282RP004F01 14

and 0.01 tonnes (0.01 tonne equated to approximately 10 litres of oil spilt).This shift may be due to changes in reporting requirements.

Figure 3.2: Distribution of Spill Size and Likelihood (normalised per installation) (UKOOA, 2006)

Large spills have become increasingly uncommon and Figure 3.2 indicates that this frequency has been close to zero in recent years. However, it can be seen from Figure 3.3 that spills from drilling rigs and support vessels make a significant contribution to those very large spills that do occur.

Figure 3.3: Distribution of Spill Size and Likelihood (normalised per topsides) (UKOOA, 2006)

3.3 Potential Spill Scenarios

Potential spill scenarios are dictated by the oil and fuel inventories on the drilling rig and associated vessels and, once the pay zone has been penetrated, by the reservoir characteristics. Small spills can occur during the operation of the drilling rig for a number of reasons and the worst case scenarios are determined by both the total inventory of the rig and the reservoir characteristics. In practice, due to precautions such as training, operating procedures and engineered solutions, the majority of oil spills are small, with a low number of larger spills.

The Kish Bank exploration well has two target reservoirs. The Primary Target Reservoir is the Triassic Sherwood sandstone and the Secondary Target Reservoir are Carboniferous sands.

3.3.1 Accidental Spill

The main spill risks associated with drilling operations is an accidental hydrocarbon release such as accidental fuel or chemical spill; rather than from drilling, depending on reservoir type.


MGE0282RP004F01 15

The most frequently expected spill size would be a small (< 1 tonne) spill of diesel oil or chemical from the rig inventory, during bulk transfer to/from the rig, leakage or during use or storage. Accidental diesel spills during bunkering are identified as a moderate risk but the expected volumes of hydrocarbon released would be generally small (0.6 tonnes) (HSE, 1995). Such a volume would disperse rapidly and will not impact along the coast.

3.3.2 Worst Case Spill Scenarios

Worst case spill scenarios that could lead to a large spill from the Kish Bank exploration well are:

A loss of well control when drilling in the hydrocarbon bearing formation or during a well test operation;

An accident, such as collision, resulting in complete loss of the rig or supply vessel.

A blow-out is the uncontrolled influx of reservoir fluids into the well. Due to the precautions taken to prevent their occurrence, they are very rare events. Uncontrolled flow is mostly associated with drilling into a shallow gas pocket or whilst drilling a deep gas well.

In light of events in overseas oil and gas industries Det Norske Veritas (DNV) carried out an assessment to estimate the probability for having a long duration oil blowout associated with the total oil & gas activity on the Norwegian and UK Continental Shelf, based on a review of UK and North Sea operation history.

Table 3.1: Predicted frequency of blow outs per well drilled based on the Norwegian and UK industries2

Therefore it is estimated that there is a frequency of 0.000123 blowouts recorded per exploration well drilled. Table 3-2 outlines the likely duration of a blowout based on the review of incidents in the UK and Norway.

The seismic surveys will provide additional information as to the likely nature of the subsurface, and should highlight shallow gas hazards.

Once the rig has been confirmed the drilling contractor will provide a finalised drilling plan, including controls, equipment and mitigation in relation to blowouts. Once this is confirmed, this document will be updated in consultation with relevant authorities. As part of Section 5 responses and responsibilities in the event of a blow out would be established and recorded in this section.

2 Scandpower 2011. Blowout and well release frequencies based on SINTEF offshore blowout database 2010 (revised). Scandpower report No. 19.101.001‐3009/2011/R3 DNV 2010. Environmental Risk Assessment of Exploration Drilling in Nordland VI. DNV report 2010‐04‐20. Rev 01.


MGE0282RP004F01 16

It should be noted that with a frequency of 0.000123 blowouts per exploration well, and if Providence drill approximately one exploration well per year, the probability of occurrence is a return period of 8130 years.

Table 3.2: Predicted frequency of blow outs by duration per well drilled based on the Norwegian and UK industries3

The study assumed about 60 exploration drillings on Norwegian Continental Shelf per year a similar contribution from exploration activity is estimated from the UKCS as there were 62 exploration drillings in 2010 and that half of them would be on an oil prospect, and that 10 % will be drilled in HPHT reservoirs, a total oil blowout frequency related to exploration drilling calculates to 0.00562 per year or a return period of 178 years.

Based on these estimates Ireland plans approximately 3 exploration wells per year (IOSEA1, 2,3 and 4, PAD 2002-2011) and therefore would have a blowout frequency of of 0.002825 per year (0.2825%) or a probability of a blowout return period of 354 years in Ireland, and therefore is highly unlikely.

If any condensate was to be spilt in the event of a loss of well control, it would disperse naturally very quickly and would not threaten the coastline. Any issue would relate to oil only and Section 5 of this document as issued to the regulator, contractor etc, will include a full response Master Plan when all information is available.

Therefore in terms of oil spill the risk is primarily related to an incident, such as a collision, could potentially cause the entire inventory of hydrocarbons stored on the MODU to be released to the sea. For MODUs in the North Sea between 1980 and 1997 a total loss accident frequency of 3.75 occurrences per 1000 unit years was recorded (Worldwide Offshore Accident Databook – Statistical Report 1998, DET NORSKE VERITAS). In practice it is most likely that any release of oil would occur over a period of time. An immediate release could, however, occur in the unlikely event that all compartment/tanks containing oil were instantaneously fractured in some way.

Typical and worst case spills that could occur during drilling operations for the Kish Bank exploration well are summarised in Table 3.1. These are dependant on the vessels and rig used

Table 3.3: Typical Operational and Worst Case Spills during Drilling Operations

Type of Oil Operational Spill Worst Case Spill

Size (tonnes)

Event Size (tonnes)

Event

Diesel 1 Transfer 1000 Loss of Rig

Lube Oil and Hydraulic Oil 0.01 Drum failure during transfer 10 Loss of Rig

Reservoir fluid 1 Well blowout 700 Loss of Rig

3.3.3 Response to worst case scenario

A master spill response plan will be developed with the Irish Coast Guard and relevant authorities. Details of how the plan will be developed will be included in Section 5 of this

3 Scandpower 2011. Blowout and well release frequencies based on SINTEF offshore blowout database 2010 (revised). Scandpower report No. 19.101.001‐3009/2011/R3 DNV 2010. Environmental Risk Assessment of Exploration Drilling in Nordland VI. DNV report 2010‐04‐20. Rev 01.


MGE0282RP004F01 17

document once the drilling rig and timelines etc are confirmed. This information document will then be updated and provided to relevant personnel as the Oil Spill Contingency Plan.

In the case of a worst cast scenario (blowout) the following details likely actions.

Initial actions

Providence, their well management company and the rig operator have primary and secondary well control procedures in place.

In the event of a well control incident, the initial response will be to close the annular blow out preventer (BOP), using the rig primary or alternate controls. A number of different override systems are also available should this fail. These include the capability to operate some of the BOP rams using a remotely operated vehicle (ROV).

Depending on when in the well construction process a blowout occurs, there may be various other methods available to control the flow of hydrocarbons to the surface. These include varying the pump rate and the use of various chemicals, such as weighting material (barite or calcium carbonate) and cement. Therefore, a contingency stock of cement and weighting fluids will be kept onboard the drilling rig. Although the time required to kill the well will be dependent on the how and why it has failed, a standard well kill operation takes between 12 and 48 hours. Once control of the well has been regained, the well can be fully abandoned with cement plugs.

Primary Control

Primary well control is usually achieved by keeping the wellbore full of a drilling fluid with a higher density than the pressure drilled. The drilling fluid programme will provide drilling fluids with higher densities than the formation pressures expected and therefore the material from the well (oil, gas or condensate) is held in place.

Capping the well

In the event of a subsea blowout, whereby the BOP has failed and gas or oil flowing into the sea, there may be a possibility to temporarily cap the well until it can be brought back under control by drilling a relief well. Once installed, this type of cap will completely seal off the well, and thus stop the oil from spilling into the sea, until the well can be brought under control and permanently closed off using cement plugs. Following the Macondo incident, the Oil Spill Prevention and Response Advisory Group (OSPRAG) within Oil & Gas UK have constructed a well cap of a modular design, which will allow installation at various points of the subsea wellhead, the blow-out preventer (BOP) or lower marine riser assembly. The cap is held in Aberdeen and is available for use by operators who have a contract in place with OSR for oil spill response.

Non-sealing subsea containment units

In those cases where the well capping method described above would not be feasible, or would take a long time to mobilise, two alternative containment units and associated cutting equipment are currently held by OSR in Southampton on behalf of BP. Although there is currently no transfer agreement between OSR and BP for the use of these devices by other operators, it is expected that they would be made available should the need arise. These 28" and 48" ‘Top Hat’ containment devices can be installed on top of a broken riser. However, these systems will not completely seal off the well, which means only part of the oil will be contained, whilst the remaining oil will continue to be released into the sea. These units also have the capability to inject hydrate inhibitors and dispersant into the produced fluids, which will aid the dispersion of the spilled oil in the sea. Before the BP Macondo well in the Gulf of Mexico was sealed with a sealing well cap, a non-sealing unit of this type was able to capture in excess of 2,700 m3 (17,000 bbl) of oil and 1.13 million cubic metres (40 MMscft) of gas per day from the overall flow rate of the spill.

Drilling a relief well

Where other options fail and should oil spill from the Kish Bank Well, the only remaining option to bring the well back under control may be to drill a relief well. An evaluation from the seismic survey, drill plan contingency and insurance to cover the cost of drilling a


MGE0282RP004F01 18

relief well in the event of a blow out or total loss of the drilling rig will be in place before drilling of the exploration well, and a relief well design will be in place prior to drilling.

3.4 Fate of Spilt Oil

3.4.1 Weathering Processes

Once a hydrocarbon is spilled it immediately begins to undergo weathering, comprising many natural, physical, chemical and biological changes (Figure 3.4, Table 3.2). Prevailing metrological and oceanographic conditions, as well as the type of oil spilt will also determine the ultimate fate of the spilled oil.

Figure 3.4: Fate of Spilled Oil (ITOPF)

Table 3.2 Fate of Spilt Oil in the Marine Environment

Degradation Agent

Description Rate and

contribution to slick removal

Diesel / Condensate

Spreading Oil will tend to spread out on the surface of water. The rate and degree to which it does this will depend upon the viscosity of the oil and the surface tension between the oil and the water. The higher the temperature, the lower the viscosity and the greater the degree and speed of spreading. Under the influence of wind the oil will become unevenly distributed. It will tend to break up into patches or ribbons, thickest in the leading edge and thinnest at the trailing edge.

Rapid cover of large areas

Very rapid spreading

Evaporation Evaporation will remove the more volatile molecules from the surface of the oil slick into the atmosphere. It will act fastest when there is a large surface area of oil exposed to the air and will increase with temperature. It will be more predominant when the proportion of lighter to heavier molecules in the oil is high and the energy in the sea and atmosphere is high (rough conditions).

Rapid, particularly for lighter oils. It may

account for 10 – 75% of removal of oil from

the sea surface depending upon the

initial type.

Major means of removal

Dissolution The soluble elements of the oil (the lighter molecules) will preferentially be removed from the slick into the water column and they will subsequently be diluted by dispersion. Aided by high energy in the sea.

Active soon after a spill occurs, but

overall it is a relatively minor pathway.

Can be important

Dispersion The oil layer on the surface of the sea is broken into small droplets which then disperse into the

An important process for removing oil from

Important


MGE0282RP004F01 19

Degradation Agent

Description Rate and

contribution to slick removal

Diesel / Condensate

water column. The rate at which this occurs and the degree to which it occurs will depend upon the composition of the oil. Aided by high energy in the sea.

the surface and facilitating bio-

degradation. Most important for the less

viscous oils.

Photolysis Light energy acting upon oil breaks chemical bonds in the hydrocarbon chains and allows it to slowly oxidise. Aided by high levels of irradiation.

Negligible over the short term in high northern latitudes

however important in the long term and

lower latitudes.

Important

Bio-degradation Biodegradation is the ultimate means of removal of free oil from the environment. This process is aided by ample nutrient supply, dispersion of oil, moderate temperatures and a high energy environment.

Minor importance in the short term but

very important in the long term.

Not important

Drift Drift of the oil slick is facilitated by wind, waves and surface water currents.

Important in distributing oil and

moving it into or out of sensitive areas.

Can be important

Figure 3.5: The rate of removal of oil from the sea surface according to type (the volume of oil and oil-in-water emulsion remaining on the sea surface is shown as a percentage of the volume spilled)

Note:

The International Tanker Owner Pollution Federation (ITOPF) has ranked oils according to their physical characteristics and likely spill behaviour into the following four categories:

Group I SG <0.8 API >45 Light

Group II SG 0.8-0.85 API 35-45

Group III SG 0.85-0.95 API 17.5-35

Group IV SG >0.95 API <17.5 Heavy

Diesel is a Group I oil under this classification. A typical light crude would be a Group II oil.


MGE0282RP004F01 20

3.4.2 Oil Spill Modelling for the Kish Bank Exploration Well

The movement and weathering of oil, from a theoretical spill arising from drilling operations associated with the Kish Bank exploration well will be modelled using the BMT OSIS version 4.1 spill model. The modelled spill scenarios are outlined in Table 3.3.

Modelling will be completed once final well details are defined, including location, timing and rig. Modelling scenarios will likely be as follows:

- Onshore trajectory modelling of total loss of diesel.

- Offshore trajectory modelling of total loss of diesel.

- Stochastic modelling of total loss of diesel.

If crude / condensate, then the following scenarios would be modelled:

- Onshore trajectory modelling of worst case flow rate for 10 days (blow-out scenario) of crude / condensate

- Offshore trajectory modelling of worst case flow rate for 10 days (blow-out scenario) of crude / condensate

- Stochastic modelling of worst case flow rate for 10 days (blow-out scenario) of crude / condensate.

Initial modelling of the drill cuttings has been undertaken and indicates North East South

3.5 Effect of Spilt Oil and Environmental Risk

Effect of Spilt Oil

The risk to the environment of a spill is the result of the probability of a spill occurring multiplied by its consequences i.e. the larger the spill, the greater it’s potential to cause damage. The closer any environmental sensitivity is to the oil, the greater its potential for damage.

The effects of oil in the environment are related to the following:

Toxicity: primarily the lighter more volatile fractions can kill or debilitate organisms;

Physical effects: smothering of plants and animals, preventing photosynthesis and respiration and causing loss of insulation to animals with fur or feathers;

Tainting: whereby the flavour of fish meat can be tainted with an ‘oily’ taste for a period following an oil spill.

The type of oil and its effects on the environment over time are shown in Figure 3.9 below. From the point that oil is spilt at sea, its composition and location will change with time. The volume of the slick will tend to decrease rapidly due to weathering by the weathering agents. For a diesel or condensate spill the principal factor removing oil from the sea is evaporation. Light oils will spread rapidly on the sea surface and, until dispersion has taken place, will move with the surface water currents and the prevailing wind.

Figure 3.6: Illustration of the Effects of Oil (Dicks, 1992)


MGE0282RP004F01 21

Environmental Risk

An environmental risk assessment has been undertaken using a matrix, plotting the probability of a given size of oil spill against its potential consequences. Spills that pose an acceptable risk are unlikely to need any specific mitigation measures beyond good housekeeping and adherence to Providence’s HSEQ Management System. A risk that requires mitigation measures does so to both reduce the probability of a spill and the environmental impacts of such a spill. Non-acceptable risks highlight areas of greatest risk to the environment where efforts should be concentrated to reduce the probability of a spill occurring.

Guidelines have been established for acceptance criteria for environmental risks posed by acute oil spills (OLF, 1994). According to OLF 1994, frequency of occurrence data may be used in place of probability data (Tables 3.3 and 3.4).

Table 3.3: OLF Event Probabilities / Frequency of Occurrence

Probability level Probability Diesel spill levels

Level 5 1x 10-04

Level 4 1x 10-03

Level 3 1x 10-02 Large Tier 2 and Tier 3

Level 2 1x 10-01 Tier 1 and small Tier 2

Level 1 1x 10-00

Table 3.4: OLF Environmental Consequence Levels

Consequence level

Category of environmental damage

Description of environmental damage

Level 1 Indemonstrable environmental damage

No demonstrable or measurable effect

Level 2 Minor environmental damage

Few fish, birds and sea mammals affected; <1 kilometre of coastline affected

Level 3 Moderate environmental damage

Some effect on fish, birds & sea mammals; restoration time <2 years; 1 to <10 kilometres of coastline affected

Level 4 Significant environmental damage

Affects animal life which will threaten the multiplicity of fish, birds or sea mammals in the influence area; restoration time 2<5 years; 10 to <100 kilometres of coastline affected; affects areas of scientific interest


MGE0282RP004F01 22

Consequence level

Category of environmental damage

Description of environmental damage

Level 5 Serious environmental damage

Affects animal life which will threaten the multiplicity of fish, birds or sea mammals in the influence area; restoration time >5 years; >100 kilometres of coastline affected; significant effect on preservation areas.

Assessment of Environmental Risk and Risk Mitigation

Location and time to beaching can be estimated using slick trajectory analyses based on spill location and volume spilled. Utilising the OLF criteria, risk matrix methodology can be applied to give an assessment of overall environmental risk from a spill. The matrices are formed from a combination of probability of occurrence (plotted vertically down the matrix) and size of spill, equating to environmental consequence (plotted horizontally across the matrix).

The overall frequency of spills is low, however small diesel spills have a relatively high frequency of occurrence compared to other oil spill scenarios and therefore plot into the high probability level in the matrix. However, as level 1 type spills, they will disperse rapidly and would normally result in minimal environmental damage. They therefore plot into the lowest matrices for environmental consequence. A diesel spill of greater than 50 tonnes has a lower frequency of occurrence but still plots into the high level of occurrence. These situations will both be classified as ‘acceptable risk’ (see Figure 3.7) providing that the precautions are taken to minimise the risk of spills, see below. Environmental effects are related to the presence of sensitive features at the time of the spill and are therefore likely to be limited to minor effects on small numbers of marine fauna such as seabirds and fish, present in the immediate vicinity of the spill.

Figure 3.7: Spill Size and Frequency versus Potential Effects


MGE0282RP004F01 23

3.6 Spill Prevention and Mitigation

3.6.1 Policy and Training

Providence’s policy is that operations will be conducted in such a manner that will minimise the risk of oil spillage and pollution. Onshore efforts in operations planning are subjected to review to identify potential risks and ensure that they are properly controlled. These include:

Programme review meetings (involving all contractors);

Pre-spud and pre-job (drilling) meetings to review the final programme in detail; and

Hazard and risk identification to test the programme for likelihood and severity of all identified risks.

On board the drilling rig (rig to be confirmed) basic oil spill clean-up training and drills will be carried out i.e. use of equipment held on board together with in house training.

Onshore, specific training involves familiarisation with the OSCP for the Kish Bank exploration well. The objective is that personnel required to respond in the event of a spill should fully understand their particular responsibilities, as well as be familiar with the OSCP as a whole. Providence will instruct the crew of the drilling rig and support vessel on the content of the OSCP prior to the commencement of operations.

Personnel who are required to respond directly, such as the staff on the support vessels, are required to have had training in the deployment and use of the response equipment located on site.

Training of all Providence and contractor staff, with responsibilities for emergency response, is on-going and regularly reviewed. Key members of the Emergency Response Team are specifically trained in oil spill response by, and are familiar with, OSR. All members of the emergency response team have been fully briefed on their responsibilities, as have members of the support team, such as the Relatives Response Team and the Public Relations Response Team. The response procedures are regularly tested by practical exercises involving both internal and external response teams.

Prior to spudding of the well, the rig crews will be formally made aware of the contents of the OSCP. Personnel who are involved in the OSCP must remain familiar with its contents and should have regular oil spill drills. In addition a live exercise is required, possibly involving deployment of shoreline booms and associated equipment. The specifics of this exercise will be dictated by the Irish Coastguard.

As part of the OSCP consultation within the PAD procedures a spill response plan will be formulated and included in Section 5, once the rig, contractor and support vessels have been established and the site survey data are available.

3.6.2 Mitigation

Well Kick

In the unlikely event of a “kick”, the well would be shut in using the BOP. Training is carried out to ensure that the correct action would be taken on the rig in accordance with its specific Well Control Procedures.

Hydrocarbon Spills

The five main sources of potential spills, from historical oil spill records, are listed in Table 3.5 with the measures being taken by the drilling rig to minimise or eliminate the risks. These are discussed further in the sections below along with measures proposed by the drilling rig in the unlikely event of a spill.


MGE0282RP004F01 24

Table 3.5: Sources of oil spills and control measures planned

Potential source of spill

Risk and control measures taken

Oil based mud If OBM is to be used, the rig’s specific safety checks and procedures for the use of OBM will be utilised throughout the period the OBM is on the rig, and any drill cuttings will be captures by a cuttings containment system before either being processed offshore or returned to shore for disposal.

Un-burnt hydrocarbons during testing

If well testing is required, the well will be tested using high efficiency burners with procedures in place to shut well immediately if any problems are encountered. Station watcher will monitor potential flare liquid drop out and raise the alarm. Surrounding sea areas will be monitored for presence of high numbers of seabirds.

Fuel or other utility fluids (e.g. diesel, lubricants)

Re-fuelling will only commence during daylight and in good weather conditions. Non-return valves will be installed on fuel transfer hoses, and operations will be supervised at all times from both the supply boat and drill rig. Rig operator will ensure crew are trained and regularly hold exercises to contain and clean up deck spills and safety store contaminated material until its ultimate disposal on shore. Training records will be held on board. Training records will be kept.

Leaks from storage tanks on the MODU

A clear record of the chemicals store will be maintained at all times and Providence will ensure compliance with the HOCNS reporting requirements. Tanks will be provided with appropriate bunding and absorbents will be provided for spill management of diesel, lube oil and stored chemicals.

Training will be provided on spill clean-up techniques, with special training provided for personnel with the responsibility for the operations valves, particularly dump valves, to make them aware of the importance to the environment of preventing accidental oil spills in general and in the correct identification and utilisation of valves prior to their use.

Loss of Rig (ship collision)

Stand-by vessel will monitor approaching shipping and patrol the 500m exclusion zone.

Notification of planned drilling programme will be made with all relevant maritime and fishing authorities.

Loss of well control Precautions to prevent loss of well control include analysis of existing shallow seismic and 3D seismic to identify shallow gas hazards, appropriate well design and engineering, well monitoring programme, BOP, well control training and emergency drills. Consequently the probability of such an event occurring is extremely low.

4 Oil Spill Response Strategy

4.1 Tiered Response

Taking into account the risk of oil spills occurring as determined by the risk assessment (refer to Section 3) a three-tiered response approach has been adopted for the Kish Bank exploration well:

Tier 1: response is that which is immediately available on site, geared for the most frequently anticipated oil spill.

Tier 2: response is for less frequently anticipated oil spills of larger size and for which external resources will be required to assist in monitoring and clean-up.

Tier 3 response is in place for the very rarely anticipated oil spill of major proportions and which will possibly require national and international resources to assist in protecting vulnerable areas and in the clean-up.

The clean-up resources and arrangements that Providence has established for each tier of response for the Kish Bank exploration well drilling programme are summarized in Table 4.1.

Table 4.1: Tiered Oil Spill Response


MGE0282RP004F01 25

Tier Size Category of Spill

Equipment and Personnel Requirement

Resources and Mobilisation Time

1 Small spill Resources in the field are able to monitor. Response will be short in duration.

Standby vessel at the well location able to monitor and track the spill.

If safe to do so, the stand by vessel may assist in the dispersion of small slicks (e.g. agitation using the propeller).

2 Medium sized spill

Requires the mobilisation of aerial surveillance to monitor the movement and dispersion of the oil.

The additional use of aerial chemical dispersant treatment may be required, only if safety dictates or sensitive areas are threatened and approval has been given by IRCG*.

Aerial surveillance and aerial dispersant* application capability provided through external resource (OSR) (refer to Table 4.2).

Aerial surveillance service utilising an aircraft type aircraft (and back up aircraft) equipped with IR, UV etc. sensing equipment and Satcom. Separate dispersant Cessna 406 aircraft and dispersant pod and stocks. Both aircraft located at Coventry airport in the UK. Aerial surveillance response available within give timeframe. The Irish Coastguard and Navy have some aircraft that may be able to respond

3 Large oil spill

In addition to the Tier 2 response, may require rapid mobilisation of regional / international resources to effectively tackle the spill. Response may be of long duration (weeks / months).

Under the National Contingency Plan a national response is likely to be required.

Access to all Tier 2 resources plus aerial chemical dispersant* treatment from OSR (Hercules with the ADDs pack and Nimbus system). Response to major spills (10,000 tonnes) within 18 hours.

If shoreline is threatened: Specialised mechanical containment and recovery equipment and skilled technicians to lead clean-up operations held by OSR (refer to Table 4.2). ‘Unskilled’ labour mobilised locally together with general purpose equipment and transport.

IRCG may activate a Marine Rescue Coordination Centre prior to the deployment of people and equipment to the scene (the nearest MRCC location is Dublin Port and Blanchardstown). IRCG hold a limited equipment stockpile for shoreline protection and clean-up (booms, skimmers and recovered oil storage) and have trained personnel to deploy it. Equipment is held at Dublin (Blanchardstown), Killybegs and Castletownbere. The maximum mobilisation time of this equipment to site would be 11 hours.

*Note: The use of dispersants in Irish waters is limited by Irish national policy and is controlled by the IRCG. This dictates that dispersants are not an optional clean-up method and that they can only be used where personnel on a facility are physically endangered by the spill.

Figure 4.1: Location of Logistics for Tier 2 & 3 Responses

This chart will be developed in conjunction with the Irish coastguard and PAD once the survey has confirmed the likely reserve type and potential and the rig has been identified.

The PAD and the Irish Coastguard will assist in the identification of the nearest resources.

For example the oil spill response in Dublin Port includes Sorbent Boom M50 (20 Bales) 300 metres of boom at trailer at Port Radio with a Kamera Skimmer: (mini skimmer) located at the Harbour Masters Offices.


MGE0282RP004F01 26

4.1.1 On-site Response

The PAD Rules and Procedures for Offshore Petroleum Exploration and Appraisal Operations specify that, for a drilling operation less than 55 km from the coast, "At Sea" response equipment must be held either ashore at the nearest port to the site area or on board a support vessel at the drilling location.

“at sea” for Kish Bank response equipment, will be determined in consultation with the IRCG and may include five tonnes of Type 3 dispersant with appropriate equipment for deployment, and is held onboard the standby vessel.

The standby vessel would have a capability to deploy booms and skimmers, and would have crew trained in the use of this equipment, and storage capability for recovered oil and contaminated water. For the Kish Bank well this equipment for use on this vessel will be held onshore Dublin Port. In the event of an incident the equipment would be onsite in a few hours, allowing for 2 hours loading at the port.

In addition, a full suite of response equipment will be available for mobilisation from OSRL’s (http://www.oilspillresponse.com) base in the UK.

Dublin Port

Standby vessels

IRCG stockpile Blanchardstown

Killibegs

Castletownbere

Southampton

Cardiff


MGE0282RP004F01 27

4.1.2 IRCG Response

Details of the Tier 2/3 equipment held by OSR are summarised in Table 4.2, with the IRCG’s national stockpile of oil spill equipment listed in Table 4.3.

Table 4.2: OSR Tier 2 & 3 Containerised Equipment

Outline of OSR Oil Spill Response Equipment

Container Principal use Equipment Quantity

OSR 1 Ship to ship transfer Likely to be a Yokohama fender 3

OSR 2 Dispersant supply for ADDS pack Bulk tanker loaded with 22,500 l dispersant

n/a

OSR 3 Aerial application Type 3 dispersant ADDS Pack 1

OSR 4 At sea containment / recovery of medium crude oils

Weir Boom system

Reserve power pack

Fassi crane VHF

Radio Box

1

1

1

1

OSR 5 Typically shoreline protection Sea sentinel boom20 metres

Sea sentinel boom 10 metres

Shore guardian boom 20 metres

Shore guardian boom10 metres

Air fan and pump box

Komara 12 K skimmer

Vacuum system

Portable buildings

Fastanks

Spate pumps

Decon + HR kit

16

10

16

16

3

2

1

2

8

3

1

OSR 6 At sea containment / recovery of medium crude to medium fuel oils

Ro-skim System (350 metres)

Ro-skim pump for tandem operation

DS250 Skimmer system

Oleophillic attachment for DS250

Sea Sentinel boom extension (130 metres)

Air fan

Upgrade power pack including air fan

Deutz power pack

GT185 skimmer

Termite weir skimmers and pumps

Roto drum heavy oil skimmer

50 T Lancer Barge

Hose reels

1

1

1

1

1

1

1

1

1

2

1

1

2

OSR 7 Typically for containment / recovery of medium to heavy crudes to medium fuel oils

Egmopol Barge 1


MGE0282RP004F01 28

Outline of OSR Oil Spill Response Equipment

Container Principal use Equipment Quantity

OSR 8 Principally for shoreline protection Sea sentinel boom 20metre

Shoreguard boom 20 metre

Anchors 30 kilogrammes

Tripping Buoys (40)

Air fan & pump box

Chain stillage

Boom support stillage

Stake box

Generator & lights

Komara 12K skimmer

Powervac

Peristaltic pump

Fastank

All Terrain vehicle

24

6

10

1

1

1

1

1

1

2

1

1

4

1

OSR 9 Principally for shoreline protection Sea sentinel boom 20 metres

Sea sentinel boom 10 metres



Anchors (10 x 30 kilogrammes)

Tripping Buoys (40)**

Air fan & pump box

Chain stillage

Boom support stillage

Stake box

Generator & lights

Komara 12K skimmer

Powervac

Peristaltic pump

Fastank

GT 185 skimmer system

Trimspeed press washer

40

20

20

10

6

3

4

3

2

3

1

2

2

1

6

1

1


MGE0282RP004F01 29

Table 4.3: IRCG National Stockpile of Oil Spill Equipment

Item Quantity Location Notes

Bla

nc

ha

rds

tow

n

Ca

stl

e B

ere

Kil

lyb

eg

s

Offshore Booms

Ro Boom 1500, 200m on reel c/w power pack Inc anchor set

6x 200m (1200m) 4 1 1

Ro Boom 1100, 200m on reel c/w power pack Inc anchor set

7x200m (1,400m) 7

Inshore Booms

Shore Guardian 750 x 20m 97x20m (1,940m) 89 4 4

Silver Beach 750x20m 20x20m (400m) 20

Neoprene Shore Guardian 750x15m 10x15m (150m) 10

Sea Sentinal 750 x 25m 62x25m (1,550m) 54 4 4

Sea Sentinal .750m x 20m x 200m on Reel 4x200m (800m) 2 1 1

Absorbent Booms

3M (each pack contains 4 x 3m) 99 packs (1,188m) 99

Drizit 125 packs (1,500m)

125

Inshore Boom Ancillaries

Boom Deployment stillages

Shore Guardian/ Sea Sentinal (per 100m)

Air Blower & Hoses

Water Pump and Hoses

Hoses & spares

17 Anchor Sets 72

Tow sets 43

Air Inflator 28

Water Pump 15

Boom Deployment Stillages

Sea Sentinal/ Shore Guardian per

6 Anchors

9 anchor chains

10 buoys

Ropes ¾” & ½”

Tow Bridles

Handtools, stakes, sledgehammers, spades etc

11

Recovery Systems

OPEC Diesel Drive oil mop system inc mop and pulleys capacity 6 tph

2 2

OM 260 Diesel Drive oil mop system inc mop and pulleys capacity 6 tph Yellow

7 7

Komara 12 K disc skimmer inc power pack Capacity 12 tph refined products to medium viscosity crudes and emulsions

5 3 2

Komara 20 K disc skimmer inc power pack Capacity 20 tph refined products to medium viscosity crudes and emulsions

7 5 2

Komara 40 K disc skimmer inc power pack Capacity 40 tph refined products to medium

1 1


MGE0282RP004F01 30

Item Quantity Location Notes

Bla

nc

ha

rds

tow

n

Ca

stl

e B

ere

Kil

lyb

eg

s

viscosity crudes and emulsions

Vikoma Powervac portable vacuum unit c/w recovery hopper, Capacity 30 tph (Beach Cleaning Max Rate)

3 3

Delta Skimmer Capacity 30 tph 3 3

Heavy Oil Recovery

Komara Star c/w power pack. Capacity 15 tph medium to high (20,000+cSt) viscosity oils and emulsions with very low free water content

3 3

Sea Devil c/w water injection & power pack.

Capacity medium to high (20,000+cSt) viscosity oils and emulsions with very low free water content

1 1

Storage

Fastank capacity 8t 27 15 6 6

Viko Tank 6 4 1 1

Shore Clean-Up

20ft container c/w ancillary response equipment for manual clean up

4 2 1 1

Salvage Pumps

Salvage fire pumps 14 4 The ICG has contracted six medium-lift Sikorsky Search & Rescue helicopters at bases in Dublin, Waterford, Shannon and Sligo

4.2 Oil Spill Quantification

It is important to determine the size of the spill so that the appropriate spill response is mounted. Where possible, calculate the volume of oil spilled from methods other than the evaluation of a spill on the sea, for example:

Volume of oil in pipe work;

Volume of diesel in a hose; and

Change in level in diesel or oil storage tank.

If an estimate of the spill size cannot be determined from platform information, a visual inspection may be made by observing the slick on the sea surface. Although this could be performed from the installation or standby vessel, if close to the spill, best estimates are made during aerial surveillance flights. This OSCP contains an aerial observation log (refer to Section 8.9) designed to assist this estimation process. When using this technique, bear in mind that the entire area of the slick may not be visible and that this can only provide an ‘order of magnitude’ estimate of the amount of oil spilled. See


MGE0282RP004F01 31

Extended Guidelines for the Use of the Bonn Agreement Oil Appearance Code (BAOAC) Annex 4, September 2003.

The following pictures, Table 4.4 and worked example should be used to assist you to make a best estimate of spill size.

Table 4.5: Estimation of Oil Quantity by Colour

Code Description – Appearance Layer Thickness Interval (µm) Litres per km2

1 Sheen (silvery/grey) 0.04 to 0.30 40 – 300

2 Rainbow 0.30 to 5.0 300 – 5000

3 Metallic 5.0 to 50 5000 – 50,000

4 Discontinuous true oil colour 50 to 200 50,000 – 200,000

5 Continuous true oil colour 200 to More than 200 200,000 – More than 200,000

(Source: Bonn Agreement Oil Appearance Code, Annex, 2003.)

Figure 4.2 shows the following appearances of oil on the sea surface:

Figure 4.2: Appearance of Oil

Method

Estimate the total extent of the area as a square or rectangle (in kilometres square) i.e. maximum extremities of the slick.

Assess the area affected by the slick in kilometres squared calculated as a percentage of the total area in (1).

Estimate the area covered by each colour of oil, calculated as a percentage of the total area affected.

Multiply the area covered by each colour by the appropriate figure in the oil quantity table above.

1. 2.

3. 4.

1. Sheen (Silvery/ grey) – code 1 2. Discontinuous true oil colour – code 4,

3. Emulsified oil – code 5 4. Emulsified oil – code 5


MGE0282RP004F01 32

Adding all of the values obtained in (4) will give the total volume of oil in cubic metres within the slick.

Convert amount of oil spilt to tonnes for the purposes of reporting

(NB: 1 barrel = 0.159 cubic metres; 1 tonne = cubic metres x 0.85 (for diesel oil); if the density of an oil is not known, assume that 1 tonne = 1 cubic metre.)

Worked Example

The maximum extremities of a slick extend to an area of approximately 30 kilometres square, and the area within this that is covered by oil is estimated to be about 75 percent, then:

Total area affected = 30 x 0.75

= 22.5 kilometres square

The percentage of the area affected that is covered by “blue” oil is 40 percent, then:

Volume occupied by “blue” oil = 22.5 x 0.4 x 1.0

= 9 cubic metres

The percentage of the area affected that is covered by “rainbow” oil is 60 percent, then:

Volume occupied by “rainbow” oil = 22.5 x 0.6 x 0.3

= 4 cubic metres

Estimated total volume of oil spilled = 9 + 4

= 13 cubic metres

4.3 Manual Calculation of Slick Movement

The oil slick will move at approximately 3 percent of the wind speed and 100 percent of the current speed. Estimating slick movement and direction may be done manually by vector addition using an estimate of current speed and wind speed as indicated in Figure 4.3 and explained in the worked example below. This provides an indication of movement until a detailed model can be run. The Marine Institute have an model that is used as part of the Oil Spill Response Plan for Dublin area.

4.3.1 Requirements

Admiralty chart for the relevant part of the North Atlantic.

Data:

Wind speed and wind direction;

Current speed and direction (use Admiralty Chart); and

Latitude and longitude of the spill location (use project co-ordinates provided in the summary sheet).

4.3.2 Construction of a Vector Diagram

Use the same units and scale for the X axis (horizontal) and Y axis (vertical).

Units can be knots or kilometres per hour (1 knot = 1.85 kilometres per hour).

(Suggested Scale: 1 centimetre to 1 knot for high wind speeds or 10 centimetres to 1 knot for lower wind speeds (less than 20 knot)).


MGE0282RP004F01 33

Plot the spill location on the graph paper (point A).

On one axis, draw a line from A in the direction of the wind to represent the distance travelled by the slick in 1 hour at 3 percent of the wind speed (multiply the speed by 0.03 to give 3 percent of the wind speed) to point B. This is the Surface Wind Drift Vector.

On the other axis draw a line from point B, the end of the Surface Wind Drift Vector in the direction of the current to represent the distance travelled by the slick in 1 hour at 100 percent of the current speed to point C. This is the Tidal Current Vector.

Draw a line from A to where it intersects the Tidal Current Vector (point C). This is the Resultant Slick Motion Drift Vector.

The length of the Resultant Slick Motion Drift Vector provides a value for the speed at which the slick is moving (or the distance moved in 1 hour). The angle of this line with the vertical axis of the graph, representing true north, (measured using the protractor) indicates the direction in which the slick is travelling.

Figure 4.3: Movement of Spilt Oil at Sea

Surface wind drift vector3% Wind velocity

(at 90 degrees to North)

In worked example below,1.7 centimetres

Tidal current vector100% Water current velocity(

t 180 degrees to North)

In worked example below, 5.6 centimetres a

Resultant Slick Motion Drift Vector(In worked example below

6 centimetres at 166 degrees to North)

(Point B)

Oil Spill Finish(Point C)

Oil Spill Location(Point A)

True North

4.3.3 Plotting Slick Movement on a Chart

The progressive movement of the oil slick should be plotted upon a chart.

Mark the co-ordinates of the rig on the chart (See Figure 1.1)

Convert the distance moved in one hour (obtained from the Resultant Slick Motion Drift Vector) to the same scale as the chart.


MGE0282RP004F01 34

Draw a line (to scale) from the marked rig location at an angle equivalent to the direction of slick movement. Note the resultant co-ordinates of the slick, these represent the predicted position of the slick after one hour.

A 24 hour prediction can be achieved by repeating steps 1 and 2 above for each hour, using the co-ordinates for the slick location as the starting point for the next iteration. The direction of the tidal current will need to be adjusted for each iteration.

Example

The wind speed is 30 knots and is blowing from the West.

A West wind blows from 270 degrees

The slick moves towards 270 degrees – 180 degrees = 090 degrees

30 knots = 30 x 1.85 kilometres per hour

= 55.5 kilometres per hour

Adjusted for 3 percent of the wind speed = 55.5 x 0.03


On a scale of 1 centimetre to 1 kilometre per hour plotted for a 1 hour period:

1 centimetre represents 1 kilometre.

1 x 1.7 = 1.7 centimetre represents 1.7 kilometres

The Surface Wind Drift Vector is drawn as a 1.7 centimetre line at an angle of 90 to the vertical axis.

The current speed is 3 knots and is flowing to the South.

A southerly current moves towards 180 degrees

3 knots = 3 x 1.85 kilometres per hour


On a scale of 1 centimetre to 1 kilometre per hour, plotted for a 1 hour period:

1 centimetre represents 1 kilometre.

1 x 5.6 = 5.6 centimetre represents 5.6 kilometres.

The Tidal Current Vector is drawn from the end of the Surface Wind Drift Vector as a 5.6 centimetres line at an angle of 180 degrees to the vertical axis.

From a vector diagram of the above:

The length of the Resultant Slick Motion Drift Vector = 6.0 centimetres and is at angle of 166 degrees to the vertical axis.

Therefore it is predicted that in 1 hour the slick will move 6.0 kilometres in a South South-East direction (towards 166 degrees).

The Admiralty chart has a scale of 1:200,000.

1 centimetre on the chart represents 200,000 centimetres = 2 kilometres.

The line drawn on the chart will be 1 centimetre x (6.0 kilometres / 2 kilometres) = 3.0 centimetres at an angle of 166 degrees.


MGE0282RP004F01 35

4.4 Oil Spill Response Options

There are various possible response options in the event of a spill these include the following:

Leave alone and monitor;

Containment and mechanical recovery;

Chemical dispersion (in the event of an emergency threatening life or with prior approval from IRCG);

On-shore clean-up.

For the Kish Bank exploration well these options are summarised in Table 4.4.

Table 4.4: Response Strategy for Oil Spills from the Kish Bank Exploration Well

Oil Type Tier 1 Tier 2 Tier 3

Diesel / Aviation Fuel Natural dispersion and monitor*

Natural dispersion and monitor*

Natural dispersion and monitor

Crude Oil** Natural dispersion and monitor*

Mechanical recovery where practical

Natural dispersion and monitor*




Persistent oil (Hydraulic and Lube)


Volume on board less than Tier 2

N/A

* If safe to do so, agitation using the propeller of the stand by vessel may assist the dispersion of small slicks. ** Note the nature of the reservoir fluid has not yet been determined. The well may be dry gas or condensate, in which case crude oil would not be applicable.

The appropriate response in a given situation will depend on the size of the spill, type of oil and its location. As a general philosophy, clean-up of oil at sea is the preferred option. Various factors must be considered, such as the proximity of the oil to land or other environmentally sensitive areas, the response resources available and the areas at risk. The response options are discussed below.

4.4.1 Leave Alone and Monitor

As described in earlier sections, natural processes will eventually degrade oil in the environment. Thus if circumstances permit, the 'leave alone' option, coupled with careful monitoring of the movement of the oil, may be the most appropriate response. The circumstances where this type of response may be adopted are:

In open water under conditions, where modelling indicates that the spill will disperse without significantly affecting environmentally sensitive areas.

In weather conditions where no other response is viable.

Oil spill movement may be predicted by manual (refer to Section 4.3) or computer methods. Small spills can generally be monitored by vessel. Larger spills can be monitored by air, using either visual observation (daylight hours only with good visibility), or Side Aperture Radar or Infra Red systems (night time and poor visibility). It is recognised that aerial observation is the best way to find, track and monitor an oil spill. The aircraft must be suitable for the operation and work to a predefined flight plan with a trained observer on board (see Aerial Surveillance Observers Log in Section 8.9).

Initial observation may be carried out from the contract helicopter, however if sustained observation was required, fixed wing aerial surveillance of the slick would be mobilised from OSR, who would place a trained observer, with observation equipment on a locally chartered aircraft.


MGE0282RP004F01 36

The movement of the oil would be independently modelled, by the oil spill contractor, using available meteorological data and updated from actual sightings from the aerial surveillance operations.

4.4.2 Containment and Mechanical Recovery

Mechanical recovery involves the physical containment then removal of oil from the sea surface, followed by the re-use or disposal of the recovered oil. The oil must be contained, concentrated, recovered, stored and eventually disposed of safely and permanently.

Containment and concentration of the oil on the sea surface is usually carried out with a floating boom, and recovery is carried out using a skimmer system. Vessels are required to manoeuvre the boom and skimmers and sufficient tanks are required for the storage and transport of recovered oil. Transport, storage and disposal of large quantities of recovered oil can pose major logistical problems. Vessels must be rated for the transport of recovered oil (M1663).

The physical constraints upon the conditions in which mechanical equipment can be expected to be operated are shown in Table 4.5 and Table 4.6. The deployment and the efficiency of these systems are low when the wind and sea conditions are at or exceed Sea States 5.

Table 4.5: Summary of Limits for Containment Booms

Constraint Limits Reference

Visibility Daylight hours unless spotlights are used

IOE, 1991

Wave Height Conservatively less than 2.0m IOE, 1991, Schulze, 1993; OSR Personal communication

Water Current Daylight hours < 0.7m/s (1.35 knots) normal to the boom

Currents < 1.54 m/s (3 knots)

CONCAWE, 1981; Schulze, 1993; OSR Personal communication

Table 4.6: Summary of Operating Criteria for Oil Recovery Devices (manufacturers various 1999)

Skimmer Type Of Oil Capacity Weather Observations

Disc skimmers

All kinds of oil, poor efficiency in emulsions

10-400m3/h collect 10-60% water with the oil

Claimed up to Beaufort Force 4-5 (1-3m waves)

Installed on board ship or a floating unit, best used with booms

Band skimmers

Work in non viscous oils

10-300m3/h 10-50% water with the oil

Efficient in calm water, low efficiency in waves

Tow speed is 1-2 knots max. The band can suffer from tearing with the presence of solids and too high towing speed

Vortex skimmers

All oils except viscous oil and emulsion

10-700m3/h 20-60% of water is recovered

Used with waves up to 1.5m

Must be towed by ship or fixed to the boats hull. To be efficient the apparatus must be towed at 1-8 knots.

Skimming barrier

All oils except highly viscous emulsions

100-2700m3/day Efficiency reduces with waves >0.5m

Must be towed at speed sufficient to ensure adequate thickness of oil reaches the pump

4.4.3 Chemical Dispersant

The use of dispersants in Irish waters is limited by Irish national policy. This dictates that dispersants are not an optional clean-up method and that they can only be used where personnel on a facility are physically endangered by the spill. The use of dispersant is controlled by the IRCG and considered on a case by case basis as an event develops (refer to Table 4.7).


MGE0282RP004F01 37

Table 4.7: Chemical Dispersant Use Checklist

Consideration Comment

Use of Dispersant The use of chemical dispersant is not part of the IRCG’s policy. Dispersant would only be considered if safety is threatened.

Product must be approved for use by IRCG

This will be considered on a case-by-case basis.

Authorisation must be obtained from IRCG prior to use

IRCG must also be notified following dispersant use

See Pro Forma in Section 8.6 for request to use dispersant prior to use and Pro Forma in Section 8.7 for IRCG notification following use of dispersant.

In the event of the threat to safety, dispersant may be used without prior approval.

Depth of water and distance from shore

Do not use dispersant in less than 20 metres of water or within one mile of such an area without consulting IRCG before hand for advice.

Environmentally sensitive area

Do not use in such an area without consulting IRCG beforehand

Will the chemical dispersant work?

Oil viscosity and state

Check efficacy by testing a sample of seawater, oil and dispersant in the ration of 400:20:1.

Oil must be amenable to the dispersant to be used. Generally a viscosity of 2000 – 3000 mPa is considered to be the upper limit although specific products may be used on heavier or emulsified oils.

In general terms dispersant will be most effective upon fresh oil.

Meteorological conditions must be suitable

Require wind and waves (energy) to mix and disperse oil and applied dispersant.

Wind speed limit Beaufort Force 4-5 and wave height 0.5-2.5 metres.

Most effective during daylight hours with visibility > 5 nm, however there is a capability to treat during the hours of darkness if this can be carried out safely and effectively.

Rate of application of chemical dispersant

Check that the application method is suitable for the dispersant to be applied. Treat at a ratio of 1:10 or 1:20 dispersant to oil.

Check the amount of oil to be treated using oil thickness as detailed in Section 4.2 - Oil Quantification.

Alter dose by changing speed of movement over the oil or by changing the application pressure within the limits allowed for the nozzles being used.

Monitor efficacy of treatment

Check that the treatment is working and review tactics accordingly.

Follow manufacturers instructions

Follow specific instructions for: - HSE/COSHH precautions during use - dosage;-application method (vessel mounted boom or aerial application) - storage and periodic efficacy test method and interval.

4.4.4 Inshore Oil Spill Clean-up

Shorelines have varying degrees of vulnerability to oil spills and the clean-up techniques must be selected accordingly. Where clean-up or coastal protection is recommended, the following options are available:

Booms to protect specific areas or contain oil;

Skimmers to remove oil from the water near the shore;

Cold/hot water hoses to wash down beaches;

Dispersant treatment of beached oil at low tide (requires permission from IRCG);

Physical removal of oil and contaminated debris; and

Natural degradation of oil.


MGE0282RP004F01 38

Clean up options should be chosen in relation to the shore type (Table 4.8). Particular attention needs to be paid to the organisation of the teams, temporary storage of oil and debris and access routes to the shore.

Table 4.8: Shorelines in Increasing Order of Vulnerability to Oil Spill Damage (Gundlach and Hayes, 1978)

Vulnerability Index

Shoreline Type Comments

1 Exposed rocky shores

Wave reflection keeps most of the oil offshore. No cleaning necessary

2 Eroding wave cut platforms

Wave swept. Most oil removed by natural processes within weeks

3 Fine grained sand beaches

Oil does not usually penetrate far into the sediment, facilitating mechanical removal if necessary. Oil may persist for several months

4 Coarse grained sand beaches

Oil may sink or may be buried rapidly, making clean-up difficult. Under moderate to high energy conditions the oil will be removed naturally within months from most of the beach face

5 Exposed compacted tidal flats

Most oil will not adhere to or penetrate into the compacted tidal flat; clean-up usually unnecessary

6 Mixed sand and gravel

Oil may undergo rapid penetration and burial; under moderate to low energy conditions oil may persist for years

7 Gravel beaches As for 6. A solid asphalt pavement may form under heavy oil accumulations

8 Sheltered rocky coast

Areas of reduced wave action; oil may persist for many years. Clean-up is not recommended unless oil accumulation is very heavy

9 Sheltered tidal flat Areas of low wave energy and high biological productivity; oil may persist for many years. Clean-up is not recommended unless oil accumulation is very heavy. These areas should receive priority protection by using booms or oil-sorbent materials

10 Salt marsh Most productive of aquatic environments; oil may persist for many years. Cleaning of salt marshes by burning or cutting should be undertaken only if it is heavily oiled

In Ireland the Local Authorities are responsible for onshore clean-up of spills via the Joint Response Committee. The details of the shore clean-up priorities are given in the national and local authority oil spill contingency plans including:-

The areas where the oil should be left and monitored;

The areas or conditions under which the oil should be dispersed;

The areas where the spill should be recovered mechanically;

The areas which should be given priority for protection by booms.

The environmental sensitivities may vary during the year and change according to perspective.

4.4.5 Storage and Disposal Sites

Recovered oil would be placed in temporary storage and transported ashore for disposal. If practical, recovered oil would be temporarily stored or disposed on the Irish mainland.

Currently Ireland does not have the capacity to handle large quantities of recovered oil, which would probably have to be transported to Europe for disposal. If large quantities of oil were expected, the availability of coastal tankers is routinely monitored and if necessary one would be chartered for storage and transport to the disposal location. The eventual disposal route will depend on the quality and quantity of oil. If possible recovered oil would be transported to a refinery as feed stock. Alternatively it would be transported


MGE0282RP004F01 39

to a temporary storage site while disposal options were fully evaluated (e.g. stabilise and landfill).

4.5 Response Strategy Decision Tree

The following tree (Figure 4.4) may be used to determine the response strategy:

Figure 4.4: Response Strategy Decision Tree

Is containment andrecovery feasible?

Is theoil a threatto safety ?

Consider mounting containmentand recovery operation.

Tier 1-Stand-by vessel on scene tomonitor and track the spill

If safe, stand-by vessel may assist indispersion of spill

Tier 2 & 3 - OSR equipment, nominalcapability of 30,000 tonnes of oil

YES

YES

YES

NO

NO

Monitoring

All spills must be monitored until complete dispersion.Small slicks may be observed from the Stand-by vessel.

Large spills will require aerial surveillance to monitor the oil.

Initial surveillance may be undertaken using the helicopter contractor.For sustained monitoring effort, consider mobilising fixed

wing surveillance from OSR

Is theoil likely to

affect seabirds atsea or reach the

coast?

NO

Tier 2 & 3 - Mobilise and deploy OSR equipment as required, nominally sufficient for 30,000 tonnes of oil

Keep upwindDo not approach oil unless safe to do so

Consider hosing down the spilled oil on the sea surfaceto reduce fire hazard and to break up oil slick

Consider leaving oil toweather naturally

Note: The use of dispersants in Irish waters is limited by Irish national policy and is controlled by the IRCG. This dictates that dispersants are not an optional clean-up method and that they can only be used where personnel on a facility are physically endangered by the spill


MGE0282RP004F01 40

5 Response Actions

5.1 Structure of the Response Organisation

Once a rig and drilling contractor have been appointed a structured response team will be formulated. In the event of a spill, the well management contractor and drilling contractor form the initial response team. This section will be updated for consultation with the relevant departments following the drilling contractor appointment and site survey. Note that the copy of this document provided to the relevant government organisations and the rig operators and contractors will include all necessary lines of communications and contact details. The following section outlines how the response teams work with examples of roles and organisations involved.

5.1.1 Response Teams

The response to an oil spill is managed by designated teams, as described below and outlined in Figure 5.1.

Emergency Management Team (EMT) – Providence/Well Management Contractor (Well Manager tbc)

The principle role of the EMT is to manage oil spill response operations for Tier 2/3 incidents, and would consist initially of the Providence Duty Manager (this role will be undertaken by the Well Management Contractor) and the Providence HSE Advisor, but may be supplemented by other Providence personnel, or well management personnel.

The role of the EMT is to:

Develop a comprehensive and up to date understanding of the emergency;

Provide support and contribute to the ERT where applicable (e.g. OSR);

Brief the Technical Director or Board Members on a regular basis;

Manage the Corporate Media Response to the emergency;

Manage the response to relatives of personnel involved in the emergency;

Co-ordinate the deployment of resources to the Business Unit.

The EMT will function out of their faculties (to be confirmed) and have constant communication with the Providence’s main office in Dublin. The EMT will also be in communications with the drilling contractors ERT (to be confirmed), the IRCG, PAD and any relevant local authorities during an oil pollution incident.

Emergency Response Team (ERT) – Drilling Contractor (t to be confirmed)

The principal aim of drilling contractor Emergency Response Team (ERT) is to co-ordinate offshore emergency operations.

The ERT will function out of the drilling contractor offices (to be confirmed) and maintain constant communication with the EMT as well as IRCG and PAD. If necessary, a representative from the ERT will travel to Providence’s EMT to advice and co-ordinate the response.

Offshore Response

Refer to Section 5.2 for response actions of offshore personnel.

The OSR Oil Spill Response Team (ORT)

The ORT if mobilised, will be primarily operating in the field, and will establish a command centre appropriate to the needs on the onshore operations. An advisor will be available to the ERT/EMT to assist with ongoing operations.


MGE0282RP004F01 41

Figure 5.1: Lines of Communication between the Response Teams

The details will be confirmed when a drilling contractor is appointed. A previous Providence example is included for information


MGE0282RP004F01 42

5.2 Offshore Response Team Actions

Initial actions in the event of an oil spill are shown in Figure 5.2 and described in the tables below.

Figure 5.2: Initial Actions Onboard the Rig

Oil Spill Observer

Notify supervisor or OIM and provide details of (refer to Oil Spill Assessment Checklist in Section 8.1):

source of spill;

current spill location;

oil type;

estimation of quantity of oil spilled (refer to Section 4.2);

any other relevant actions.

Contact all personnel in the vicinity of the leak or spill and warn of potential hazard.

Act as instructed by the OIM.

If SAFE to do so, stay in vicinity of the leak or spill and continue observation.

If SAFE to do so, take any reasonable action to contain or reduce leak or spill.

If off the installation (e.g. helicopter, standby vessel) contact the OIM and give details of observations.

Notify Drilling Contractor and notify Providence Drilling

Superintendent


MGE0282RP004F01 43

OIM

Receive report on spill from Oil Spill Observer and take charge of situation.

Ensure safety of personnel, the installation and any vessel or rig within 500 metres.

If SAFE to do so, immediately initiate actions to identify source and stop leakage at source.

Inform the Providence Drilling Supervisor and the drilling contractor Offshore Duty Manager.

Initiate a chronological log of events and actions taken (refer to Section 8.8). Maintain until stand down.

Confirm source and estimate quantity of oil spilt. Classify spill size and determine likely slick movement (refer to Sections 4.2 and 4.3).

If no risk to personnel or installation, request standby vessel to track spill location and take samples of spilt oil (refer to Section 8.4).

Inform the IRCG of the spill as quickly as possible and supply them with preliminary details (refer to Section 8.5). Request assistance from the drilling contractor Offshore ERT if required.

In the event of a Tier 1 spill, unless there are compelling reasons to do otherwise, the spill will be monitored and allowed to disperse naturally. If the slick is in the vicinity of the installation and is a threat to its safety, onshore dispersant resources should be requested from MRCC Dublin (Tier 2&3 response). IRCG must be consulted prior to spraying and notified following the cessation of spraying (refer to Section 8.6 and 8.7).

Ensure all other installations and vessels in the vicinity have been informed of the spill.

At the end of the incident stand down response and prepare report of the incident for Providence management.

Providence Offshore Drilling Supervisor

On being notified of an incident by the OIM, report spill to Providence Duty Manager providing details of spill and action taken. Dispatch Oil Spill Report Form by fax to confirm details (refer to Section 8.5).

Work with the OIM to reduce or prevent further oil leakage without endangering safety of personnel.

Provide regular written (hourly) updates to the Providence EMT on extent of spill and actions taken.

In the event that on-site resources (Tier 1) are not adequately able to respond to the existing spill or if existing spill is likely to escalate, request Tier 2/3 assistance from the Providence EMT as appropriate.

Monitor spilt oil and response operations and advice Providence EMT when spill emergency is over, keep a chronological log of events (refer to Section 8.8).

At the end of the incident prepare report of the incident for Providence management.

5.3 Onshore Response Team Actions

5.3.1 Drilling Contractor’s ERT / Providence EMT

The below tables provide an overview of key roles and responsibilities in drilling contractor ERT and Providence’s EMT.

Offshore Duty Manager (drilling contractor)

Mobilise drilling contractor ERT if appropriate. Provide technical support to OIM.

Provide logistical support and communications with the rig and standby vessel.

Maintain a chronological log of events (refer to Section 8.8).

Record all details of conversations.

Ensure that a “lessons learned” profile is available quickly so that remedial action and the possible upgrading of procedures can take place.


MGE0282RP004F01 44

Providence Duty Manager (EMT)

In conjunction with the on-scene personnel (OIM and Drilling Supervisor on the rig (tbc) decide whether to call out the EMT. The EMT determines the overall response strategy and monitors its effectiveness.

Inform the HSE Advisor as soon as possible.

Maintain contact between rig and EMT, relay information, list of notifications made from the rig and requests for mobilisations of resources as required. Provide technical support to the Drilling Supervisor on the rig.

Record all details of incident and all incoming information (refer to Section 8.8).

Assess scope and potential of incident and the probable effects on the project.

Ensure detailed documentation of all stages of the incident is being maintained.

Maintain a chronological log of events.

Record all details of conversations.

Maintain contact and ensure full briefing of Media Response Team is being achieved.

Continue to co-ordinate EMT response actions and monitor the actions of other teams and groups.

Ensure the Drilling Contractor ERT and all Government Agencies are being continuously updated.

Ensure any parties that might be affected by the oil spill have been notified.

In the event of a Tier 2/3 spill mobilise OSR.

Initiate "Stand down" only when satisfied that all matters relating to the incident have been dealt with as far as is practicable and that the local teams and groups no longer require support.

Request return of all personnel logs, incident reports, communications copies etc. This may be in the form of a collated report. All original documentation from all working locations must be preserved.

Ensure that a comprehensive report of the incident with chronological log of events, persons notified and all supporting documentation is prepared for Providence.


HSE Advisor (EMT)

Maintain a chronological log of events; ensure detailed documentation of all stages of the incident is maintained. Record details of conversations.

Ensure primary alerts and notifications have been made as necessary (refer to Section 6), giving full information on location of incident, time, quantity spilled, movement and current status. Record times of notifications. Contact the Local Authority if spill threatens coast (refer to Section 6).

Determine whether aerial surveillance should be mobilised to monitor the spill. Initial, daylight aerial monitoring should be carried out using the Providence crew change helicopter. Night time aerial surveillance or sustained aerial surveillance should be carried out using the OSR fixed wing surveillance service (Section 4.1). Surveillance should be carried out twice daily until the oil has completely dispersed.

Normally aerial surveillance alone is sufficient to monitor natural dispersion of diesel, however if the slick is in the vicinity of the installation and is a threat to its safety, dispersant may be sprayed to reduce this threat. IRCG must be consulted prior to spraying and notified following the cessation of spraying (refer to Section 8.6 and 8.7).

Track slick and determine likely movement (towards other installations / environmentally sensitive areas / coastal regions). Use OSR modelling service.

Arrange for photographs and sample to be taken of the slick.

Ensure aerial surveillance (aircraft) has been mobilised if required. In the event of sustained aerial surveillance, the slick must be observed twice daily and reports made to IRCG and PAD (Use Aerial Surveillance Observers Log - Section 8.9). A bird observer may join the surveillance operation if required. In consultation with the trained observers seek advice on the following:

Overall extent of oil slick;

Direction of movement, especially noting other installations and vessels in the vicinity;

Proximity to environmentally sensitive areas;

Areas in need of urgent clean-up measures;

Need for additional assistance and back-up services;

Progress and dispersion of slick during clean-up operations.


MGE0282RP004F01 45

HSE Advisor (EMT)

Ensure adequate supervision of all clean-up operations is by trained personnel

Maintain involvement in oil spill clean-up response until instructed to “stand down”.

When instructed by the Duty Manager, commence “Stand-down” procedures as follows:

Ensure all government agencies previously notified are informed of final state of clean-up procedures.

Ensure all local authorities, contractors, vessels, aircraft, external resource suppliers, etc are contacted, notify of End of Incident and request stand down.

Ensure return of equipment used, replace materials, chemicals, etc with correct documentation.

Ensure you are still accessible to support personnel in compiling their report.


5.3.2 Onshore Oil Spill Response Team (ORT)

In the event of an oil spill, additional specialists trained in oil spill response and clean-up techniques may be required. Generally these specialist personnel will be contracted directly or under advisement, from OSR (Tier 2 and 3) and IRCG (Tier 2 and 3).

An Oil Spill Advisor may be mobilised to the EMT if required. For aerial dispersant treatment specialist personnel will be contracted via OSR, to fulfil two principal roles to scout for and direct this response, namely the Oil Spill Observer and the On Scene Commander. These roles would report to the Providence EMT.

Oil Spill Advisor (OSR)

Provide support by phone or join the Providence EMT

Obtain fullest information on the incident from the EMT.

Obtain information from the OSCP and through discussion with the HSE Advisor identify location of environmentally or other sensitive areas and map. Update as appropriate.

Keep a chronological log of events for input to incident log.

Liaison as necessary with government authorities (e.g. IRCG, PAD and Local Authorities).

If clean-up is not considered necessary, monitor movement and dispersion of the oil slick.

If clean-up is considered necessary, advise the EMT on the equipment and manpower requirements. Mobilise these facilities as soon as they are made available.

Monitor progress of the response and advise the EMT of any further actions necessary (e.g. further clean-up, disposal of recovered oil, environmental surveys, etc).

Oil Spill Observer (Surveillance Plane)

On receipt of notification of an incident by the OSR Oil Spill Advisor board the dedicated surveillance aircraft.

Obtain fullest information on the incident from the EMT or OIM if mobilised from offshore.

Estimate probable position and movement of the oil slick.

Brief pilot on objectives of the flight.

Visually monitor the oil spill and provide up to date information on its movement and state.

Locate the oil slick and obtain and log the following essential information:

time;

location and size of the slick;

visual appearance of the slick;

estimate quantity of oil on the surface;

speed and direction the slick is moving;

location of environmentally sensitive areas.


MGE0282RP004F01 46

Oil Spill Observer (Surveillance Plane)


Report information to the On-Scene Commander and EMT.

On-Scene Commander (Offshore)

Obtain fullest information on the incident from the EMT (if mobilised onshore) and OIM (if mobilised offshore).

Set up Operations Centres and communication links with the following:

Providence EMT;

OIM (if appropriate);

Oil Spill Observer;

Clean-up Vessels/Clean-up Supervisors;

Control the offshore clean-up operation of the spill.


Obtain update on situation from Oil Spill Observer and direct response aircraft.

Monitor progress of the clean-up operations and co-ordinate any additional action necessary as instructed by the EMT.

Advise the EMT of progress and request further assistance/ back up if necessary.

Oil Spill Clean-up Supervisor

Go on location as requested by EMT.

Control the individual clean-up operations on each clean-up vessel.

Obtain fullest information on the incident from the On-scene Commander.


Prepare oil spill clean-up equipment and proceed to the location as directed by the On-scene Commander/ EMT.

Advise On-scene Commander of progress and request further assistance/back-up if necessary.


MGE0282RP004F01 47

6 Reporting Requirements

The reporting requirements for oil spills vary according to the size of the oil spill, the location of the oil slick and the environmental resources or human interests that are threatened by it. Whatever the size of the oil spill the incident is to be reported to drilling contractor Duty Manager by the OIM and the Providence Duty Manager by the Offshore Drilling Supervisor, by telephone, immediately. There is also a requirement to report the incident to IRCG and the PAD (refer to Section 8.5 for Oil Spill Report Form).

Table 6.1, below, summarises the reporting requirements. Contact telephone and fax numbers are provided in Section 7.

Note: if chemical dispersant use is considered, the information required by IRCG when requesting permission to use chemical dispersant is listed in Section 8.6 and following the use of dispersant in Section 8.7.

Table 6.1: Summary of Reporting Requirements

Notify this person or organisation

No

tifi

ca

tio

n t

o b

e m

ad

e b

y:

<1

to

nn

e (

sm

all

sp

ill)

1-2

5 t

on

ne

s (

me

diu

m s

pil

l)

>2

5 t

on

ne

s (

larg

e s

pil

l)

Sp

ill

is l

ike

ly t

o e

nte

r te

rrit

ori

al

wa

ters

or

ma

y r

ea

ch

th

e c

oa

st

Pri

or

to d

isp

ers

an

t u

se

, u

se

, u

nle

ss

us

ed

to

pro

tec

t th

e

sa

fety

of

the

rig

Fo

llo

win

g u

se

of

dis

pe

rsa

nts

OIM Receives notice from spill observer

Offshore Duty Manger OIM


OIM

Providence Duty Manager SDS

Providence HSE Advisor SDM

IRCG OIM

PAD OIM

Local Authority HSE Advisor

OSR (Tier 2/3 response) SDM

OIM = Offshore Installation Manager

SDS = Providence Offshore Drilling Supervisor

SDM = Providence Duty Manager

= Telephone and follow-up with fax


MGE0282RP004F01 48

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MGE0282RP004F01 49

7 Contact Telephone and Fax Numbers

Organisation Contact Telephone Faxsimile 24 Hr. Telephone Mobile or E-Mail

Providence Resources Plc & Drilling Contractor

Providence Resources plc

Ireland

Duty Officer / HSE Advisor

TBA TBA TBA TBA

Providence Energy plc

London TBA TBA TBA TBA TBA

Drilling Contractor

(Rig manager)

(Drilling Superintendent)

TBA TBA TBA TBA

Department of Transport, Leeson Lane Dublin 2

Irish Coast Guard (IRCG)

Hugh Barry

&

Station Officer

MRCC Dublin 24hour Operations Room:

+353 (0)1 662 0922

+353 (0)1 662 0923

+353 (0)1 678 2304

MRSC Malin Head:

+353 (0) 74 9370103

+353 1 662 0795

+353 (0) 74 9370206

+353 (0)1 662 0922

[email protected]

[email protected]

[email protected]

Marine Environment Division Caoimhin O’Ruairc +353 1 678 3412 +353 1 678 3419 [email protected]

Department of Communications, Energy and Natural Resources, 29 - 31 Adelaide RoadDublin 2

Petroleum Affairs Division (PAD) Technical Section

Noel Murphy +353 1 678 2712 +353 1 678 2619 [email protected]

Petroleum Affairs Division (PAD) Administration Section

Ciarán ÓhÓbáin +353 1 678 2690 +353 1 660 4462 [email protected]


MGE0282RP004F01 50

Organisation Contact Telephone Faxsimile 24 Hr. Telephone Mobile or E-Mail

Health and Safety Authority

Dublin

Limerick

+353 1890 289 389

John Kennedy

+353 1890 289 389

+353 1 614 7000

+353 1890 289 389

+353 61 419559

+353 1890 289 389

[email protected]

Local Authorities

Dún Laoghaire-Rathdown County Council

Environment Officer

+353 1 2054817 n/a

Gwynedd County Council, Wales

Oil Pollution Officer Gwynn Hughes

+44 2487 50262 (Ext.301) n/a

Contractors

Oil Spill Response (OSR) Duty Manager +44 (023) 80-331-551 +44 (023) 80-331972


MGE0282RP004F01 51

8 Checklists and Pro Forma Templates

The following checklists and pro forma templates are provided to assist information gathering, the decision making process and notifications.

8.1 Oil Spill Assessment Checklist OIL SPILL ASSESSMENT CHECKLIST

This checklist is designed to assist those personnel who have the responsibility of assessing the oil spill incident. These personnel are likely to be:

Person Sighting Spill

Offshore Installation Manager (OIM)


STEP GUIDANCE

Determine Essential Details

Location of pollution incident

Source of spill

Oil type

Extent of oil spill

Time of incident

Potential hazardous circumstances

Any other relevant information (Particularly: is spill contained or ongoing?)

Assess Safety Hazards Until otherwise established, assume oil spill is giving off potentially dangerous light ends (i.e. gas or hydrocarbon vapours).

ELIMINATE IGNITION SOURCES

Approach Oil Spill from upwind to reduce effects of vapours

APPROACH ONLY IF CONSIDERED SAFE TO DO SO!

Determine Oil Spill Source

If source unknown, investigate with care.

Instigate actions to stop spillage at source.

IF SAFE TO DO SO!

Estimate quantity of Oil released if exact amount unknown

Refer to Section 4.2 - Oil Spill Quantification.

Assess prevailing and if possible future weather conditions

Determine:

Wind speed and direction

State of tide and current speed

Sea state

Predict oil fate; determine direction and speed of oil movement in addition to weathering characteristics

Refer to Section 4.3 – Manual Calculation of Slick Movement


MGE0282RP004F01 52

8.2 Incident Briefing Checklist BRIEFING CHECKLIST

This checklist is designed to facilitate an effective response team briefing and should be used by the OIM and SBV Master when briefing personnel under their command.

Fax completed BRIEFING CHECKLIST/S to the Providence EMT for inclusion in permanent record.

STEP NOTES

Specify Safety Hazards

Extent of Problem

Size of spillage, type of oil, source

Slick Trajectory

Tide and Wind conditions

Response actions

Strategies to consider

Resource mobilisation

Equipment and personnel

Planning Cycle

Meetings schedule

Additional Information

Communications, Waste

Disposal, Weather Forecast


MGE0282RP004F01 53

8.3 Personal Log Checklist PERSONAL LOG CHECKLIST

This checklist is designed to facilitate and provide consistency in the response teams log keeping.

ITEM GUIDANCE

Safety Hazards Note potentially unsafe response activities and measures taken to mitigate the hazard.

Record all accidents / near miss incidents regardless of how serious or potentially serious the result.

Initial Notification Record time of notification of oil spill incident and the name of the person informing you.

Daily Activities Keep a daily record of all responses activities undertaken, including time and location.

Also include:

Meetings attended

Instructions received / given

Site visits and movements

Contacts with outside agencies

Personal Contacts Generate a list of relevant contacts made, including contact details.

Photographic/Video Records Note time and location of any photographs/ video taken.

Oil Distribution Make sketches of oiled area with notes.

Site Supervision Keep a record of all staff under supervision, including hours of work etc.

List of all equipment utilised.


MGE0282RP004F01 54

8.4 Oil Sampling Checklist

Action Notes

The sample should be taken in a clean container (as provided in the spill sampling kit).

Metal containers should be avoided since they may interfere with subsequent fingerprinting

Care should be taken to sample the oil only.

The SBV is provided with dedicated oil sampling kits which include all the equipment necessary for the sampling of spilt oil on the sea surface, including oil adsorbent pads.

The following sample sizes provide guidance as to amounts required for laboratory analyses.

For freshly spilled, relatively non-emulsified oils take at least 100ml.

For emulsions take at least 500ml.

If these quantities cannot be obtained, a sample should still be taken.

Carefully store samples. Ensure jars are stored in a safe place away from heat and light

Label or accompanying documentation should contain the following information.

Sample Identification No.

Date, time and place of sampling;

Name of Company;

Method of sampling;

Purpose for which sample was taken;

Source if known or suspected;

Particulars of any photos or supporting evidence

Providence Drilling Supervisor to send sample to shore for analysis


MGE0282RP004F01 55

8.5 Oil Spill Report Form

Pro forma for use in reporting (by fax) oil spills from Offshore Installations. IRCG and PAD may be notified from the drilling rig by the OIM.

TO IRCG FAX:

PAD FAX

Please complete giving units of measurement indicated

A. Operator: Field Name:

B. Date: Time Pollution Observed:

Identity of Observer/Reporter:

Operator/Contractor Reporting:

C. Location and Extent of Pollution:

Installation: Fixed/Mobile Installation?:

Latitude: Longitude:

Extent of Pollution: tonnes

D. Wind Speed: knots Wind Direction (from): degrees

E. Sea State (1-8): or Wave Height: metres

Tidal Info: Tide direction (to); deg

Speed: knots

F. Type of Oil: (e.g. crude, diesel, condensate, hydraulic fluid, kerosene, base oil etc. NB for base oil give % oil content)

Appearance:

G. Source of Pollution:

Cause of Pollution

H. Photographs taken:

Samples taken for analysis:

I. Forecast of likely effect or landfall and time:

J. Other authorities informed:

K. Steps taken to prevent re-occurrence:


MGE0282RP004F01 56

8.6 Information Required by IRCG Prior to Approval to Spray Chemical Dispersant

Name of authority or organisation requiring approval:

Name of contact, telephone and fax number to be used:

Locality of spill – (in degrees of Latitude and Longitude):

Oil type or description of appearance if not known. If crude, what type?

Volume of oil spilled – preferably in tonnes:

Source of spill:

Potential for further spill:

Description of slick – including dimensions and colour:

Volume and name of dispersant for which approval is requested:

Other methods of response being applied or considered and assistance being sought (e.g. IRCG):

Local fisheries consideration (such as seasonal fisheries, advice given to fishermen):

Local wildlife considerations, e.g. whether migrant birds are present:

Tide, type and speed and time of HW/LW particularly:

Wind and weather (e.g. ‘Moderate breeze NW’ or ‘Overcast drizzle’):

Sea state:


MGE0282RP004F01 57

8.7 IRCG Notification Following Use of Dispersant

IRCG FAX. NUMBER :

SENT BY:

Incident No. Date:

Volume and Type of Oil:

Location:

Remedial Action Taken:

Name and Type of Oil Treatment Product:

Date of manufacture:

Efficacy last tested (if applicable):

Comments on Effectiveness:

Report made to IRCG by:

Other Remarks:


MGE0282RP004F01 58

8.8 Oil Spill Log

Name: Team: Role: Location:

DATE / TIME

COMMUNICATION / ACTION TAKEN / NOTES


MGE0282RP004F01 59

8.9 Aerial Surveillance Observers Log

SURVEY DETAILS

Incident Date Observers

Aircraft Type Call Sign Area of Survey

Survey Start Time Survey End Time Average Altitude Remote Sensing Used

Weather Conditions

Wind Speed (knots) Wind Direction

Cloud Base (feet) Visibility (nm)

Time High Water Time Low Water

Current Speed (knots) Current Direction

SLICK DETAILS

Slick Grid Parameters by Lat/Long Slick Grid Parameters by Air Speed Slick Grid Dimensions

Length Axis Width Axis Length Axis Width Axis Length Nm

Start Latitude Start Latitude Time (seconds) Time (seconds) Width Nm

Start Longitude Start Longitude Length Km

End Latitude End Latitude Air Speed (knots) Air Speed (knots) Width Km

End Longitude End Longitude Length Km

Total Grid Area Km2

Oil Code Colour % Cover Observed

Total Grid Area Area Per Oil Code Factor Oil volume

0 Clean Km2 Km2 0 m3 /km2 m3

1 Silver Km2 Km2 0.1 m3 /km2 m3

2 Rainbow Km2 Km2 0.3 m3 /km2 m3

3 Black/dark brown Km2 Km2 100 m3 /km2 m3

4 Brown/Orange Km2 Km2 1000 m3 /km2 m3


MGE0282RP004F01 60

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9 References

Anatec (2006) Project A1543 – West Ireland Shipping Study, Anatec UK Ltd. Report to the Petroleum Affairs Division, April 2006.

Anatec (2011) Project Kish Banks Shipping Assessment, Anatec UK Ltd. Report to the Providence May 2011

Bonn (1999) Bonn Agreement Pollution Observation Log 1999.

Bonn (1983) The Bonn Agreement for Co-operation in dealing with Pollution of the North Sea by Oil and Other Harmful Substances 1983.

E & P (1992) E and P Forum, Hydrocarbons Emissions Database 1992.

Geraci JR (1990) Physiologic and Toxic Effects on Cetaceans. Cpt 6 in Geraci JR & St. Aubin DJ (eds.) Sea Mammals and Oil: Confronting the Risks. San Diego, California. Academic Press. pp 167-197.

Gundlach ER and Hayes MO (1978) Vulnerability of Coastal Environments to Oil Spill Impacts. Marine Technology Society Journal. 12: 18-27.

Holand P (1997) Offshore Blowouts, Causes and Control. Gulf Publishing ,Texas.163 p. ISBN 0-88415-514-5.

JNCC / ESAS (2000) Seabird vulnerability data for the Irish Sea.

Northridge SP, Tasker ML, Webb A and Williams JM (1995) Distribution and relative abundance of harbour porpoises (Phocoena phocoena L.), white-beaked dolphins (Lagenorhynchus albirostris Gray), and minke whales (Balaenoptera acutorostrata Lacepede) around the British Isles. –IRCG J. ,mar. Sci., 52:55-66.

NORSOC (1998). Risk and Emergency Preparedness Analysis. NORSOK Standard Rev.1. March 1998.

Oil and Gas UK (formerly UKOOA) (2006) Report on the Analysis of DTI UKCS Oil Spill Data for the period 1975-2005

OSR, (2007). OSR Yearbook.

Petroleum Affairs Division (PAD) (May 2007), Rules and Procedures Manual for Offshore Petroleum Exploration and Appraisal Operations.

SINTEF (1995). Offshore Blow-out Database Version 2 1995.

UKDMAP ver.3. 1998 Proudman Oceanographic Laboratory. UKDMAP ver. 3. 1998 Proudman Oceanographic Laboratory.

WOAD, (1998). Worldwide Offshore Accident Databank. Statistical Report 1998. DNV Technical Norge. P.O. Box 300, N-1322 Høvik, Norway.

WFD, Well Flow Dynamics 25 (2007). Blowout and Kill Simulation Study, Shell Exploration Well, West Dooish prospect, Leiv Eiriksson Deepwater Drilling Campaign.

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