Oil & Gas UK Supplementary Guidance On The RIDDOR Reporting Of Hydrocarbon Releases Mid 2011 discussions were held around the reporting criteria for small releases. It was agreed that there was a need to update the existing guidance, focussing on the limit for releases which are RIDDOR reportable. A workgroup was set up in March 2012 to develop new Supplementary Guidance for HCR Reporting to ensure accurate and reliable approaches to HCR reporting. New draft guidance was issued for review end Nov 2013 and presentations made to: Major Hazards Management Forum Health & Safety Forum Step Change’s Asset Integrity Steering Group IADC HSE All comments have now been received and incorporated into the guidance. All comments have been addressed. Comments were mostly requests for clarification and suggestions for improvements.

Deliverables Guidance Assessment Tool Presentation + Notes Assessment tool (excel spreadsheet) which contains the calculations supporting the guidance, ensures consistent understanding of the methodologies used to calculate the reportable limits, all references are in the public domain. This presentation – for presenting to your teams and management. Ensures a consistent roll out of the guidance. If a more technical presentation is planned then the basis for that can be taken from the Major Hazard Management Forum presentation which was presented in 2013. Oil & Gas UK Members can download this from the MHMF extranet.

Objectives of Workgroup Produce supplementary guidance that is Fully aligned with RIDDOR 2013 requirements Well-understood by the industry Consistently applied by the industry Primarily focussed on petroleum hydrocarbon releases Also includes assessment on non-petroleum hydrocarbon releases Workgroup kick off March 2012 Objectives defined and communicated to Major Hazards Management Forum Objectives are… Main focus… Main body of guidance 15 pages Rest of document is examples and appendices to support the guidance Key requirement was transparency of work, hence the detail in the appendices Important requirement as previous guidance does not provide justification for the suggested reportable limits

Petroleum Hydrocarbon Releases Reportable Limit Major Previous Guidance Significant 2014 Guidance Minor Reportable Limit This guidance is focussed on the reportability limit threshold – it will not affect the reportability of anything that is obviously a dangerous occurrence. Existing guidance and RIDDOR text is not sufficiently clear – the grey area Some operators reported lots of very small releases and others would only report the most significant releases The new guidance draws a line to eliminate the grey area, and backs this up with documented references and calculations The location of the line answers the question “which releases could cause a specified injury to, or the death of, any person?” Not Reportable Number of releases

Structure of Guidance Regulatory Requirements Review of DO relating to Hydrocarbon Releases (HCR) Methodology for Assessing RIDDOR Reporting of Petroleum Hydrocarbon Releases Define key words and phrases Reporting flow chart Technical Assessment Defines Reportable Limits Case Studies Worked Examples Appendices Consequence Analysis Application of Methodology to Non-Petroleum Hydrocarbon Fluids High Water Content Liquids The guidance focuses primarily on the assessment of reportability for Petroleum Hydrocarbon Releases under RIDDOR DO 75. Section 2 of this document provides the relevant excerpt from RIDDOR for DO 75. Additionally, Section 2 provides an overview of where other types of hydrocarbon releases are reportable under other sections of RIDDOR, including Wells Releases, Subsea Releases and Non Petroleum Hydrocarbon releases. This is summarised at the end of Section 2 in a table. (This table is also included in this presentation) Section 3 of the guidance provides definitions of the key components of DO 75 and explains how each of these components is then used in determining the reportability of a petroleum hydrocarbon release. A flowchart is provided in Appendix A to summarise the decision process for assessing reportability. The final stage of the decision process for assessing reportability is the “potential for the release to cause death or a specified injury”. Section 4 provides the detail on the technical assessment of the potential consequences of a petroleum hydrocarbon release (i.e. jet fire, pool fire, fireball, etc.) and defines reportable limits based on the potential for these consequences to cause “death or a specified injury.” The final section in the main body of the report provides a number of worked examples, covering a variety of different types of petroleum hydrocarbon release. This section is intended to show application of the guidance and reportable limits in practice. Users of the guidance are encouraged to provide additional examples to OGUK over time for inclusion in future revisions of the guidance. The remainder of the document is appendices and back-up technical analysis to support the main body of the document. These sections provide further information on the consequence analysis methodology, how the methodology for petroleum HCRs can be applied to non-petroleum HCRs (DO 77) and how high water content liquids should be treated. The reportability flowcharts are also included in Appendices A and B.

Regulatory Requirements – RIDDOR 2013 Release of petroleum hydrocarbon 75 The unintentional release of petroleum hydrocarbon on or from an offshore installation which – (a) results in – (i) a fire or explosion; or (ii) the taking of action to prevent or limit the consequences of a potential fire or explosion; or (b) could cause a specified injury to, or the death of, any person. Within DO 75 there are key word and phrases that are critical in determining whether a release is reportable. Each of these has been defined in the guidance. For example: Unintentional Petroleum Hydrocarbon Fire or explosion Taking of action.. Consequences Specified injury (a)(i) deals with an ignited event and is always reportable. There is no reportable limit associated with this event. (a)(ii) deals with the unignited event and therefore needs detailed assessment. There is a clear link between taking of action and consequence however consequence in (ii) is not explicitly defined in RIDDOR but it is defined in (b) therefore consequence is taken to mean “death or a specified injury”. Taking of action on its own does not mean the release is automatically reportable. The release must be of a certain size (rate or quantity released) before potential fire or explosion can cause death or a specified injury i.e. must exceed a reportable limit. Injury comes before death therefore the development of a reportable limit must be based on injury. Not reportable - Intervention actions taken solely for the purpose of carrying out a repair PROVIDED the release rate or quantity released is below the reportable limit. (b) Deals with other attributes of the release such as HC/H2S mixture (toxicity), narcosis of C5+, asphyxia, etc. Specified Injury – Defined in RIDDOR - A “specified injury” is defined in RIDDOR regulation 4(1)(a) to (h). For a potential fire or explosion this means: 4(i)(e) Any burn injury (including scalding) which— covers more than 10% of the whole body’s total surface area; or causes significant damage to the eyes, respiratory system or other vital organs; All other specified injuries defined in regulation 4 consider equivalent to regulation 4(1)(e). Also note that the consequence is dealing with a single person and is therefore not a MAH. MAH for fire and explosion is death or major injuries to persons (plural). RIDDOR is a higher standard than MAH regulations. In all cases it is important to consider the potential consequence of a release rather the probable consequence of a release e.g. probability of ignition.

Technical Assessment – Potential for Death or a Specified Injury Petroleum Hydrocarbons Well Fluids, Natural Gas, Natural Gas Liquids, Condensate, Crude Oil Continuous & Discrete Releases Gas, Vapour, Mist, Liquid Consequence Analysis Continuous Release - Jet Fire Continuous Release - Pool Fire Discrete Release - Fireball Discrete Release - Pool Fire Flash fire, Explosion, Toxic Cloud, Asphyxia, Narcosis - See Guidance Petroleum Hydrocarbons Emphasise definition of Petroleum Hydrocarbon – fluids that come from reservoir and are processed. Excludes fluids such as diesel, lube oil, helifuel, methanol, etc. “Petroleum hydrocarbon” - In relation to DO 75, petroleum hydrocarbons are deemed to be reservoir fluids processed by, or conveyed to or from an offshore installation, namely; well fluids; natural gas; condensate; natural gas liquids (NGLs); crude oil Releases of liquefied natural gas (LNG) on an offshore facility, with the potential to cause death or a specified injury will be reportable under DO75 as the composition will be mainly natural gas. Release or escape of substances other than petroleum hydrocarbons may also be RIDDOR reportable under DO 77. Continuous & Discrete Read definition from Guidance Emphasise difference in duration of release: Discrete – Seconds, Continuous – minutes No specific time defined for transition from discrete to continuous, this will be based on potential consequence of release and based on judgement Fluids All phases considered in guidance Consequences All potential consequences considered both unignited and ignited Assessment showed for consequences in last bullet that either the potential for death or specified injury was not credible or reportable limit for jet & pool fire will be reached before reportable limit for these other consequences Main body of guidance focuses on first four bullets

RIDDOR DO 75 Assessment Flowchart Release of Petroleum Hydrocarbons Defined in previous slide Confirmed Not explicit in RIDDOR 2013 definition but was in RIDDOR 95. We have retained this as it is an important step in determining if a release is reportable. Indication on fixed, temporary or portable fire & gas detectors Manual detection Any other evidence that demonstrates that a loss of containment occurred Not spurious Unintentional Unplanned or uncontrolled Not planned release from vent or sample point Fire or Explosion Ignition Guidance does not define ignition Automatic Executive Action Leading to stoppage of plant Systems are designed to respond to potential major accident hazards Other Action & Potential for Death or Specified Injury This addresses taking of action which can be initiation of isolation & blowdown, removing people from the area, not starting up following a release, etc. Taking action in itself does not mean the release will be reportable For potential for death or a specified injury the release rate or quantity release must exceed a certain limit, this is the reportable limit developed in the Technical Assessment In Summary For a HCR on or from an offshore installation to be RIDDOR reportable it needs to: Be a release of petroleum hydrocarbons; and Be confirmed; and Be an unintentional release; and Result in a fire or explosion; or Initiate automatic executive action; or Require the taking of other actions to prevent or limit the potential for death or a specified injury to any person, from: Potential fire or explosion; or Another hazard not covered by the preceding sections of this guidance and as described in Section 3.6.

Reportable Limits Type of Release Phase Hazard Fluid Reportable Limit Continuous Gas / Vapour / Mist Jet Fire Natural Gas Natural Gas Liquids Condensate Crude Oil 3 kg/hour (0.0008 kg/s) OR 20% LFL at 0.5 m Liquid Pool Fire 100 kg/hour (0.028 kg/s) Discrete Fireball 0.15 kg 3 kg 10 kg 30 kg Table 1, page 17. Simple reportable limit for each release type Combines the effects of all hazard types, but the worst cases are jet fire, pool fire, fire ball, pool fire (respectively) Harm criteria documented in detail It is the responsibility of the duty holder to determine the actual release rate 20% LFL at 0.5m is an alternative to a calculation and is equivalent to 3 kg/hour – not a statement about the hazard at 0.5m

Regulatory Requirements Unignited Release RIDDOR 2013 Dangerous Occurrence RIDDOR Reportable Limit OIR/12 Wells DO 20 No All releases Pipelines DO 21 Yes (See HSE Website) Only if release is within 500m zone Release of petroleum hydrocarbons DO 75 (See Sections 3 & 4) All RIDDOR DO 75 reportable releases Release of non-petroleum hydrocarbons DO 77 (See Section 5) Not required Ignited Release RIDDOR 2013 Dangerous Occurrence RIDDOR Reportable Limit OIR/12 Wells DO 20 No All releases Pipelines DO 21 Only if release is within 500m zone Release of petroleum hydrocarbons DO 75 All fires & explosions Release of non-petroleum hydrocarbon fluids DO 76 Not required This table provides an overview of where offshore releases are reportable under different sections of RIDDOR including whether an OIR/12 submission is required. This includes both unignited and ignited releases. The reportable limits for DO 21 are already defined on the HSE website. For DO 75 and DO 77, reportable limits are defined in this OGUK Guidance. Note that OIR/12 forms are not required for non-petroleum hydrocarbons either ignited or unignited.

Forward Plan Go Live 1 April 2014 Guidance Assessment Tool Presentation + Notes Feedback Workshop October 2014 Usability of Guidance Requirement for further guidance Additional Examples Assess impact of EU Offshore Safety Directive April 2015 (subject to HSE guidance availability) The guidance will be published on 1 April 2014 and available for download from Oil & Gas UK website. Towards the end of 2014 a review of the guidance will be held; helpful if operators can collate feedback and examples over this period to assist the review. The impact of the EU Offshore Safety Directive will be assessed and any amendments incorporated as needed once the new requirements have been incorporated into UK regulation and HSE guidance

Guidance on Hydrocarbon Release Reporting